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Ezel / Tax Rulings / TX
TX 8509L0667C07 Sales and/or Use Tax (State,Local,MTA) 1985-09-30

Could a signed shipper's letter of instruction plus a house bill serve as Texas proof of export?

Short answer: Yes. A freight-forwarder-signed SLI accompanied by a house airway, ocean, or rail bill was acceptable proof under Section 151.307(b)(4).

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This page answers the general question as of 1985. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1985
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 is an official 1985 Texas Comptroller taxpayer-response letter based on a specific shipper's-letter-of-instruction form supplied by a freight forwarder, completed by the consignor, and signed by the forwarder on receipt of the goods. It expressly says different facts could change the opinion. Current export, freight-forwarder, shipper-instruction, bill-of-lading, and sales-tax documentation rules may differ, and STAR documents may no longer represent current policy even when not marked superseded. Letters on STAR can support detrimental reliance only for the taxpayer to whom the letter was directly issued under 34 Tex. Admin. Code Rules 3.1 and 3.10. Taxpayer-identifying details are redacted. 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) is the authoritative source for any reliance.

Plain-English summary

The freight forwarder supplied the shipper's-letter-of-instruction form to the consignor, the consignor completed it, and the forwarder signed it when receiving the goods.

The Comptroller said the signed SLI, accompanied by a house airway, ocean, or rail bill, was acceptable proof of export under Tax Code § 151.307(b)(4).

Common questions

Was the signed SLI enough by itself? No. It had to be accompanied by the specified house bill.

Which house bills qualified? Airway, ocean, or rail.

Who signed the SLI? The freight forwarder when receiving the goods.

Citations and references

  • Tex. Tax Code Ann. § 151.307(b)(4) — proof-of-export provision applied in the letter.

Source

Original ruling text

September 30, 1985

Dear ***:

Thank you for sending a copy of a shipper's letter of instruction (SLI)
for our review.

You explained in our telephone conversation that the SLI forms are
supplied by a freight forwarder to a consignor, completed by the
consignor, and signed by the freight forwarder when he receives the
goods.

The signed SLI accompanied by a house airway, ocean, or rail bill is
acceptable as proof of export under Tex. Tax Code Ann. Sec. 151.307(b)(4).

This opinion is based on the facts presented. If there are additional
or different facts, the opinion may change.

If you have any questions or need more information, please call us at
1-800-252-5555 toll free from anywhere in Texas. You may write us at the
Tax Administration Division.

Sincerely,

Tax Policy Section
Tax Administration Division

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