Revenue and Taxation Code section 24320


Income derived from the operation of aircraft or a ship or ships by a corporation organized under the laws of a foreign country shall not be included in gross income, and shall be exempt from the taxes imposed by this part if:

(a)

The aircraft are registered or the ships are documented under the laws of the foreign country;

(b)

The income of the corporation is exempt from national income taxes by reason of a treaty or agreement between such foreign country and the United States which provides for an equivalent exemption to corporations organized in the United States; and

(c)

Units of government (other than at the national level) within such foreign country do not impose a tax upon corporations organized in the United States with respect to income derived from the operation of aircraft registered or ships documented under the laws of the United States.

Source: Section 24320, https://leginfo.­legislature.­ca.­gov/faces/codes_displaySection.­xhtml?lawCode=RTC§ionNum=24320.­ (updated Jan. 1, 1969; accessed Jul. 14, 2025).

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Verified:
Jul. 14, 2025

§ 24320's source at ca​.gov