The New York State Department of Taxation and Finance has concluded that a Canadian vendor that registers as a vendor for sales tax purposes may issue resale certificates to its suppliers to avoid paying tax on purchases of materials it intends to resell. Advisory Opinion, TSB-A-16(4)S (N.Y.S. Dep’t of Taxation & Fin., Feb. 22, 2016). The Petitioner seeking advice is a Canadian contractor, operating only in Canada but purchasing raw materials from vendors both inside and outside New York, which it then resells to an affiliate in New York, retaining ownership of the raw materials during at least part of the time the materials are in New York. The Department concluded that, in order to provide a valid resale certificate to its vendors, the Petitioner must first register for sales tax purposes, and then can purchase materials for resale without paying tax if the sales meet all the other necessary criteria.