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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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395.0000 Occasional Sales—Sale of a Business—Business Reorganization—Regulation 1595

Annotation 395.2549

(l) Sales Between Parent and Subsidiaries


395.2549 Transfer of Vehicles Between Subsidiaries. Company A and Company B are wholly-owned subsidiaries of Company C. Company A issues bonds the proceeds of which are used by Company C to pay debts owed by Company B. As part of the bond issue, Company B is required to transfer title to 1,000 of its fleet vehicles to Company A. This constitutes a sale of the 1,000 vehicles by Company B to Company A. Tax is due on the purchase price of these vehicles regardless that both B and A are wholly-owned subsidiaries of C. Companies A and B are each separate corporations and are, therefore, regarded as separate persons under the Sales and Use Tax Law. 7/1/97. (M98–3).