Ezel / Tax Rulings / CA

Were inflatable life rafts and their packaged survival kits exempt under California's watercraft exemption?

Short answer The raft was exempt, but the official sources conflict on the survival kit. The annotation says a sealed kit is a component part; its linked June 2, 1967 opinion says survival-kit items are separate commodities and not exempt. That conflict is unresolved in the published record.
State
CA
Ruling
Annotation 600.0047
Tax type
Sales and Use Tax
Issued
1967-06-02
Issued by
California State Board of Equalization
Requested by
A redacted inquirer about inflatable rafts and packaged survival equipment
Topics
component parts watercraft exemption
Source
View Original PDF

Apply this to your situation

This page answers the general question as of 1967. Ask about yours and see what current California tax law says, with citations.

Currency note: this ruling is from 1967
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: CDTFA's current Annotation 600.0047 and its linked California State Board of Equalization opinion conflict materially. The annotation is dated June 21, 1967 and says sealed survival kits are component parts; the linked opinion is dated June 2, 1967 and expressly says survival-kit items are not components and are not exempt. This page does not infer which statement controls. The issued_date field follows the linked source document's own date. 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

Both official sources agree that the described inflatable life raft had the same status as a lifeboat and that its sale was exempt.

They conflict on the equipment packaged with the raft. CDTFA's annotation says survival kits sealed inside are watercraft component parts. The linked June 2 opinion says the opposite: survival-kit items are not components of the raft, their collateral use with it does not change that result, and optional packs on the vendor's price list show they were separate commodities.

Because the annotation and its supporting document point in opposite directions, the published material does not provide a reliable single answer for the survival kit.

What this means for you

Marine-safety suppliers, vessel operators, and tax advisers

Do not extend the raft exemption to packaged survival equipment solely from this annotation. Confirm current treatment from a controlling statute, regulation, or agency determination that resolves the published conflict.

Common questions

Q: Was the inflatable life raft exempt?

A: Yes. Both sources treat the described raft like a lifeboat.

Q: Was the survival kit exempt?

A: The official sources conflict, so this record does not support a definitive answer.

Q: Why is the issued date June 2 rather than June 21?

A: June 2 is the date printed on the linked opinion. June 21 appears in the annotation summary.

Citations and references

  • CDTFA Annotation 600.0047, annotation text dated June 21, 1967
  • Linked State Board of Equalization opinion dated June 2, 1967

Source

Original ruling text

600.0047

June 2, 1967

Dear
Your letter of April 14 questions the taxabiJity of inflatable life rafts and the survival equipment packaged with such rafts. Our determination is that the type of inflatable life raft you described in your letter would have the same status as a life boat. Therefore, the sale of these inflatable rafts would be tax exempt. However we have consistently held that items generally described as components of survival kits are not components of the life boat itself (or life raft in this case), and therefore do not enjoy a tax exempt status. Collateral use of the kit with the raft is not inconsistent with a determination that the kit is not a component part of the raft. Furthermore the price list of the vendor sets forth several optional survival packs which denoted their being considered a separate commodity. If you have further questions in this area please feel free to write. Very truly yours, E.H. Stetson Tax Counsel

By _ _ _ _ _ _ _ __

A. Wells Peterson

AWP:lt
bee: San Francisco - District Administrator

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