Ezel / Tax Rulings / CA

Did California treat Wake Island and Canal Zone shipments as exports, and did that alone exempt a sale?

Short answer The annotation says yes to export status, but a sale was exempt only if regulation requirements were met. The PDF names neither places nor authorities.
State
CA
Ruling
Annotation 325.1240
Tax type
Sales and Use Tax
Issued
1950-06-29
Issued by
California State Board of Equalization
Requested by
An unidentified June 1, 1950 conference participant who orally asked whether shipments to two PDF-redacted destinations counted as exports for sales-tax purposes
Topics
conference foreign destination legal research sales tax
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 June 29, 1950 Board tax-counsel letter answers an unidentified participant's oral question at an undocumented June 1 conference. The PDF redacts both destinations, cites only unnamed statutes and decisions, and gives no transaction or regulation. CDTFA's current annotation supplies Wake Island and Canal Zone and adds that sale exemption depends on regulation requirements, but it neither identifies nor reproduces that regulation. The sources omit the requester, parties, goods, contract, price, title, possession, carrier, route, shipment, delivery, use, evidence, tax amount, filing, audit, assessment, payment, claim, appeal and later outcome. This advisory response does not bind another shipment. Check current territorial status, export, contract, delivery, use, documentation and sales-and-use-tax law. This summary is informational only and is not legal or tax advice.
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

At a June 1 conference, an unidentified person orally asked whether shipments to two destinations counted as exports for California sales-tax purposes. The supporting PDF redacts both place names; the live official annotation identifies Wake Island and the Canal Zone.

After research, tax counsel said shipments to both places would be regarded as exports under the statutes and decisions the office had found. The PDF identifies none of those authorities.

The live annotation adds a separate limit: a sale of goods shipped there was exempt only if the regulation's requirements were met. Neither source names or reproduces that regulation or its conditions.

No party, goods, contract, price, title, possession, carrier, route, shipment, delivery, use, evidence, tax amount or proceeding is supplied. Export classification therefore is not proof that any particular sale qualified.

The PDF's redacted sentence reads “shipments to --- and to the ---s exports,” an incomplete form preserved as published rather than reconstructed from the annotation.

Common questions

Which destinations does the supporting PDF name?

Neither. Both are redacted. Wake Island and the Canal Zone come from the live official annotation, a separate official evidence layer.

What did the letter conclude?

It said the two redacted destinations would be regarded as exports under unidentified statutes and decisions found in counsel's research.

Did export status automatically exempt a sale?

Not according to the live annotation. It conditioned exemption for goods shipped there on meeting the regulation's requirements.

What were those regulation requirements?

The sources do not say. No regulation number, text, delivery test, documentary rule or other condition is supplied.

Was a completed shipment or tax result reviewed?

No. The source answers an oral categorical question and contains no identified transaction, tax computation, filing, audit or later outcome.

Citations and references

  • Unidentified statutes and decisions — referenced but not cited or reproduced
  • June 1, 1950 oral conference inquiry — described but no conference record supplied
  • Official Annotation 325.1240 — identifies both destinations and adds the regulation condition

Source

Original ruling text

325.1240

STATE OF CALIFORNIA

STATE BOARD OF EQUALIZATION

June 29, 1950
In answer to your oral inquiry at our conference on June 1 concerning whether we regard shipments to --- and to the ---s exports for purposes of determining the applicability of the sales tax, our research into the matter indicates that shipments to these two places would be regarded as exports under such statutes and decisions as we have been able to find.

Very truly yours,

E. H. Stetson
Tax Counsel

cc

What does the law say today, for your facts?

This ruling is from 1950. Ezel checks current California tax law against your situation and cites the authority it relies on.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace