California Code, Revenue and Taxation Code - RTC § 6010.11

“Sale” and “purchase,” for the purpose of this part, do not include any transfer of a qualified mass commuting vehicle pursuant to a safe harbor lease arrangement described in Section 168(f)(8) of the Internal Revenue Code of 1954, as amended by Section 208 of Public Law 97-248, Section 5 of Public Law 97-354, and Section 102 of Public Law 97-448, or pursuant to a sale-leaseback or lease-leaseback arrangement which includes a safe harbor lease arrangement. For purposes of this section, “qualified mass commuting vehicle” means a qualified mass commuting vehicle as defined in Section 103(b)(9) of the Internal Revenue Code of 1954.