BILL ANALYSIS                                                                                                                                                                                                    





                                                                  AB 969

                                                                  Page  1


          GOVERNOR'S VETO
          AB 969 (Eng)
          As Amended August 20, 2007
          2/3 vote

           ----------------------------------------------------------------- 
          |ASSEMBLY:  |45-33|(May 29, 2007)  |SENATE: |21-16|(September 5,  |
          |           |     |                |        |     |2007)          |
           ----------------------------------------------------------------- 
           
          ASSEMBLY:       46-29    (September 7, 2007)                 

          Original Committee Reference:    REV. & TAX.  

           SUMMARY  :  Replaces permissive provisions with respect to  
          reporting use tax liability on an acceptable tax return with  
          mandatory provisions.  

           The Senate amendments  : 

          1)State legislative intent to require individuals and businesses  
            that failed to report and pay their liability for use tax to  
            the Board of Equalization (BOE) to report and pay the use tax  
            liability on a return filed with the Franchise Tax Board  
            (FTB).

          2)State legislative intent that the same rights and remedies  
            available under the Sales and Use Tax (SUT) Law are available  
            with respect to use tax liabilities reported on a return filed  
            with FTB. 

          3)Make minor technical corrections.

           AS PASSED BY THE ASSEMBLY  , this bill:  

          1)Required every person that had an obligation to report and  
            remit use tax to BOE, but failed to do so, to report and remit  
            qualified use tax on an acceptable tax return for all  
            purchases made on or after January 1, 2007.  Specifically:

             a)   Defined "acceptable tax return" as an original income  










                                                                  AB 969

                                                                  Page  2


               tax return timely filed with FTB;

             b)   Defined "qualified use tax" as the use tax due under SUT  
               laws other than use tax imposed on:  i) a vehicle, vessel,  
               or aircraft; ii) a lessee of tangible personal property;  
               and, iii) purchasers of cigarettes or tobacco products for  
               which the purchaser was registered with BOE as a cigarette  
               or tobacco products consumer;

             c)   Permitted an individual using the "married, filing  
               separately" filing status with FTB to elect to report  
               either one-half of the qualified use tax or the entire  
               qualified use tax on his/her separate California personal  
               income tax return.  If an individual elected to report  
               one-half of the qualified use tax, the election was not  
               binding with respect to the other half of the qualified use  
               tax due;

             d)   Provided that all penalties and interest imposed under  
               the SUT, and rules with respect to claims for refunds or  
               credits apply to the qualified use tax reported on an  
               acceptable tax return.  Considered all qualified use tax as  
               timely reported and remitted for purposes of the SUT if it  
               was reported and remitted on a timely filed acceptable tax  
               return;

             e)   Allowed BOE to make determinations for understatements  
               of qualified use tax reported on an acceptable tax return  
               within a three-year period; 

             f)   Established the order for application of payments  
               received on an acceptable tax return as amounts due under  
               the personal income or corporation tax laws, then qualified  
               use tax; and,

             g)   Prevented a person otherwise required to hold a seller's  
               permit or to register with BOE from using the procedures  
               set out in this bill.

          2)Eliminated the January 1, 2009 sunset requiring FTB to provide  
            a line for payment of use tax on the tax return forms it  










                                                                  AB 969

                                                                  Page  3


            administered and amended various provisions of existing law to  
            conform to those changes.

           FISCAL EFFECT  :  BOE estimates the total dollar amount of unpaid  
          use tax by consumers is over $400 million but the expected  
          revenue increase from this bill is $6 million per fiscal year.

           COMMENTS  :  The author states that AB 969 will raise public  
          awareness of the California use tax and increase compliance  
          among the growing number of California consumers that use  
          electronic commerce.  The author attributes the minimal use of  
          the existing FTB forms to misleading language:  Use of the term  
          "elect" adds to the misconception that reporting use tax  
          liabilities is optional.  The author states, "By clarifying that  
          consumers are required to report and pay use tax liabilities on  
          their income tax returns after failing to pay BOE directly, this  
          measure will enable both tax practitioners and consumers to have  
          a better understanding of their obligation to properly report  
          use tax liabilities."

          FTB analyzed data on use tax payments reported on income tax  
          returns for the three tax filing periods.  The total amount of  
          use tax reported was:  $2.8 million in 2004 (for tax year 2003);  
          $4.6 million in 2005 (for tax years 2004); and $5.5 million in  
          2006 (for tax year 2005).  Other facts gleaned from FTB's  
          receipt of use tax payments in 2004 include:  taxpayers  
          preparing their own tax returns were eight times more likely to  
          report use tax owed than taxpayers filing tax returns prepared  
          by tax professionals; tax returns prepared by tax professionals  
          represented 63% of all returns received by FTB but prepared only  
          16.6% of the returns with use tax declarations.  Reporting use  
          tax on an income tax return protects the taxpayer from late  
          payment penalties, but some tax professionals advise their  
          clients reporting use tax due is voluntary.  Additional problems  
          arise if tax software companies do not allow the election in  
          their tax programs.

          BOE believes requiring consumers, who fail to report use tax to  
          BOE, to report and remit the use tax on their income tax returns  
          will cause both consumers and tax practitioners, including tax  
          return preparers, to be more aware of current law about unpaid  










                                                                  AB 969

                                                                  Page  4


          use tax.    

          Clearer statements related to use tax obligations will assist  
          taxpayers to satisfy those obligations.



           GOVERNOR'S VETO MESSAGE  :

          "Although increasing use tax reporting is desirable, I have  
          concerns that the effective date of January 1, 2008, is too soon  
          for taxpayers to compile adequate records of their purchases  
          that are subject to the use tax for calendar year 2007.   
          Further, I would like to see a plan to better educate
          taxpayers on the use tax, as I suspect that many taxpayers have  
          little knowledge of the tax and may unknowingly fail to pay it."


           Analysis Prepared by :  Kimberly Bott / REV. & TAX. / (916)  
          319-2098              


                                                                 FN:  
                                                            0003617