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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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U


565.0000 United States Contractors

Annotation 565.1804

(e) Title-Passage Clauses


565.1804 Title Passage at Out-of-State Point. An out-of-state construction contractor enters into a contract with the United States to improve realty in California. The contract provides for passage of title to all property when payment is received. The contractor purchases property outside California and fabricates the property outside California. The property is not installed in California until after payment is received. Since title passed on payment, and payment occurred before the property was brought into California, no tax is due. The property belonged to the United States when it entered the state. 2/24/95.