Ezel / Tax Rulings / CA

Did California tax chrome plating used machinery rolls differently from plating new rolls?

Short answer Yes. Plating used rolls was repair and the plater consumed unitemized materials; plating new rolls was taxable production or fabrication.
State
CA
Ruling
Annotation 315.0600
Tax type
Sales and Use Tax
Issued
1950-09-26
Issued by
California State Board of Equalization
Requested by
A business having machinery rolls chrome plated
Topics
chrome plating used property new property repairs fabrication
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1950. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1950
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This 1950 opinion applied historical Rulings 15 and 26 and distinguished used machinery rolls from new rolls. For used rolls, its consumer treatment depended on the plater making no separate charge for materials. Current plating, machinery, new-versus-used-property, repair, fabrication, materials, and invoice rules control today.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

California treated chrome plating customer-furnished used machinery rolls as repair or reconditioning. If the plater made no separate charge for materials, the plater consumed those materials: tax applied to their selling price to the plater, not to the plater's charge to the customer.

Chrome plating new machinery rolls was a step in producing, fabricating, or processing the finished rolls, so tax applied to the plater's charge.

Common questions

Was plating used machinery rolls treated as repair?

Yes.

Who paid tax on unitemized plating materials?

The plater, on the materials sold to it.

What about new machinery rolls?

The plater's charge was taxable.

Citations and references

  • Historical Sales and Use Tax Rulings 15 and 26

Source

Original ruling text

315.0600

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION
1572 Chrome-Plating of used machinery rolls.

September 26, 1950

Gentlemen:
This is in answer to your letter of September 20 with respect to the application of the State sales tax to charges for chrome plating machinery rolls which you furnish to the plater. Assuming that the machinery rolls are used rolls, plating of them is regarded as a repair or reconditioning operation. In general, the application of the tax to a repair or reconditioning of used or worn articles by plating is governed by the second paragraph of sales and Use Tax Ruling 26. Accordingly, the plater is regarded as the consumer of the materials used in the plating operation, if he does not make a separate charge for the materials furnished in connection with such repairs. Thus, the tax would apply to the sales price of the material to the plater, and not to the plater's charges to you. If the machinery rolls which are plated for you are new, the plating of such rolls is regarded as a step in the production, fabrication, or processing of the finished roll, within the meaning of Ruling 15, copy enclosed. In this case, as indicated by said ruling, the tax applies to the plater's charge.

Very truly yours,

R. G. HAMLIN
Associate Tax Counsel

RGH:HB
cc:

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