BILL ANALYSIS
SB 32 x8
Page A
Date of Hearing: February 24, 2010
ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
Charles M. Calderon, Chair
SB 32 x8 (Wolk) - As Amended: February 11, 2010
SENATE VOTE : 21-14
Majority vote. Fiscal committee.
SUBJECT : Taxation: federal conformity.
SUMMARY : Changes California's specified date of conformity to
federal income tax law from January 1, 2005, to January 1, 2009,
and thereby, generally conforms to numerous changes made to
federal income tax law during that four-year period.
Specifically, this bill :
1)Conforms or partially conforms to, among other provisions,
the following federal provisions relating to the:
a) Federal tax treatment of certain disaster mitigation
payments. [The Disaster Mitigation Payments Act (Public
Law (P.L.) 109-7)].
b) Federal treatment of electric transmission property,
certain atmospheric pollution control facilities, nuclear
decommissioning cost, natural gas distribution lines,
natural gas gathering lines, and amortizable Internal
Revenue Code (IRC) Section 197 intangibles. [The Energy Tax
Incentives Act of 2005 (EITA) (P.L. 109-58)].
c) Effective date of exception from suspension rules for
certain listed and reportable transactions and tax
technical provisions of the Gulf Opportunity Zone Act of
2005 (P.L. 109-135).
d) Modification of active business definition under IRC
Section 355, treatment of loans to qualified continuing
care facilities, distributions involving disqualified
investment companies, taxation of certain settlement funds,
capital gains treatment for certain self-created musical
works, amortization of expenses incurred in creating or
acquiring music or music copyrights, and the application of
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earnings stripping rules to partners that are corporations.
[The Tax Increase Prevention and Reconciliation Act of
2005 (P.L. 109-222) and the Tax Relief and Health Care Act
of 2006 (P.L. 109-432)].
e) Clarification of treatment of self-employment for
purposes of the limitation on state taxation of retirement
income. [The Clarification of Treatment of Self-Employment
for Purposes of the Limitation on State Taxation of
Retirement Income (P.L. 109-264)].
f) Reform of funding for self-employed defined benefit
pension plans, funding rules for multiemployer defined
benefit pension plans, and general reforms of charitable
contribution reporting. [The Pension Protection Act of
2006 (PPA) (P.L. 109-280)].
g) Inflation indexing of gross income limitations on
certain retirement savings incentives and allowance of
additional Individual Retirement Account (IRA) payments in
certain bankruptcy cases. (PPA, P.L. 109-280).
h) Waiver of the early withdrawal penalty for distributions
made from a governmental plan to a qualified public safety
employee and penalty-free withdrawals from retirement plans
for individuals called to active duty. (PPA, P.L.
109-280).
i) Modified treatment of certain charitable contributions
and reporting by exempt organizations. (PPA, P. L.
109-280).
j) Frivolous tax submissions, sale of property by judicial
officers, and exclusion of gain from sale of principal
residence by certain employees of the intelligence
community. (PPA, P.L. 109-432).
aa) Federal penalty on erroneous refund claims, modified to
provide an exemption for individuals with adjusted gross
income of less than $250,000 (in the case of a married
individual filing jointly or a surviving spouse), and
$125,000 in any other case. [The Small Business Work
Opportunity Act of 2007 (SBWOTA), P.L. 110-28, Section
8247].
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bb) Federal extension of mortgage debt forgiveness until
January 1, 2013, modified to increase the state's
limitation on the amount that can be excluded from gross
income from $250,000 (or $125,000 in the case of a married
individual filing a separate return) to $500,000 (or
$250,000 in the case of a married individual filing a
separate return). [The Mortgage Forgiveness Debt Relief
Act (MFDRA), P.L. 110-343, Division A, Title III, Section
303 and the Emergency Economic Stabilization Act of 2008
(EESA), P.L. 110-343)].
cc) Exclusion from income for benefits provided to Emergency
Medical Services volunteers and firefighters. (SBWOTA,
P.L. 110-28).
dd) Increase in age of minor children whose unearned income
is taxed as if it is parents' income. (SBWOTA, P.L.
110-28).
ee) Federal penalty on understatement of a taxpayer's
liability by a tax return preparer, in modified conformity,
to incorporate the federal rule that the penalty will be
the greater of a base amount ($250 for the first-tier
penalty and $5,000 for the second-tier penalty) or 50% of
the income derived (or to be derived) by the tax return
preparer. (EESA, P.L. 110-343, Division C, Title V,
Subtitle A, Section 506).
ff) Special rule encouraging contribution of capital gain
real property for conservation purposes, dedication of
endangered species recovery expenditures, depreciation
schedule for race horses, and information reporting for
commodity credit corporation transactions. (Heartland,
Habitat, Harvest, and Horticulture Act of 2008, P.L.
110-246).
gg) Special tax treatment of distributions, contributions,
exclusions, and disposition of amounts paid to, or made by,
individuals called to active duty, other service members,
and employees of the Intelligence Community. (The Heroes
Earnings Assistance and Relief Tax Act of 2008, P.L.
110-245).
hh) Various tax incentives related to the low-income housing
tax credit. (The Housing and Economic Recovery Act of
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2008, P.L. 110-289).
ii) Special rules for tax treatment of executive
compensation of employers participating in the Troubled
Assets Relief Program, modified tax treatment of certain
payments to controlling exempt organizations, and
charitable contributions of property. (EESA, P.L.
110-343).
jj) Treatment of certain reimbursements from governmental
plans for medical care and modification of penalty for
failure to file partnership and "S" corporation returns.
[The Worker, Retiree, and Employer Recovery Act of 2008,
P.L. 110-458].
aaa) Exclusion from gross income for energy property grants
provided to a taxpayer by the Secretary of Treasury for
qualified property placed in service during either 2009 or
2010 year.
2)Provides that the state shall not conform to certain federal
provisions, including, among others:
a) The seven-year recovery period for motor sports racing
track facilities. (EESA, P.L. 110-343, Division C, Title
III, Section 317).
b) The five-year recovery period for certain farming
business machinery and equipment. (EESA, P.L. 110-343,
Division C, Title V, Section 505).
c) The enhanced charitable deductions for contributions of
food inventory. (EESA, P.L. 110-343, Division C, Title
III, Section 323).
d) The enhanced charitable deductions for contributions of
book inventory. (EESA, P.L. 110-343, Division C, Title
III, Section 324).
e) The federal changes made to the determination of a small
refiner for purposes of the depletion deduction. (EITA,
P.L. 109-58, Section 1328).
EXISTING LAW conforms the state's tax code, in many instances,
to provisions contained in the federal IRC. California does not
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automatically conform to new federal legislation. Rather,
California may conform to specific enactments at the federal
level or may conform to the IRC as of a specified date. The
last IRC to which California conformed was that in effect as of
January 1, 2005.
FISCAL EFFECT : According to the Franchise Tax Board (FTB)
staff, SBx8 32 has the following revenue effect:
-------------------------------------------------------------------
| Summary Revenue Estimates for SB 32 x8, as Amended February 11, |
| 2010 |
|-------------------------------------------------------------------|
| |
-------------------------------------------------------------------
|--------------------------+----------+---------+---------+---------|
|Conformity Provisions | 2009-10 | 2010-11 | 2011-12 | 2012-13 |
|--------------------------+----------+---------+---------+---------|
|Tax Revenue Totals | |-$20,623,0|-$21,610,|-$12,460,|
| | -$23,400,000| 00 | 000 | 000 |
-------------------------------------------------------------------
|Penalty and Interest | | | |$16,350,0|
|Totals | $2,870,000| $9,800, 000|$13,600,000|00 |
|--------------------------+----------+---------+---------+---------|
| Totals of |-$20,530,0|-$10,823,0|-$8,010,0|-$3,890,0|
|Conformity Provisions | 00 | 00 | 00 |00 |
-------------------------------------------------------------------
COMMENTS :
1)Author's Statement . According to the author's office, "SBx8
32 is a vital measure conforming state tax law to federal tax,
and includes provisions that provide needed relief to
struggling homeowners, ensure that renewable energy projects
are not unduly taxed on federal grants, and provides needed
conformity to federal tax law, easing tax preparation for
taxpayers and tax preparers alike. This measure works to
prevent onerous taxation of distressed Californians who are
already struggling to protect their homes, their largest
investment, as many Californians face foreclosure and are
forced to walk away from their homes; the last thing they
should have to think about is paying taxes on debt they
couldn't repay. This measure puts an end to this onerous
application of tax law. Additionally, since tax credits are
never considered income, taxing renewable energy production
grants would treat the renewable energy production industry
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inequitably and would add additional costs onto these projects
need for job creation and energy sustainability. It is
important that we avoid this kind of unnecessary roadblock to
economic growth as our state works to rebuild its financial
prosperity."
2)The importance (and conundrum) of conformity . When changes
are made to the federal income tax law, California does not
automatically adopt such provisions. Instead, state
legislation is needed to conform to most of those changes.
Conformity legislation is introduced either as individual tax
bills to conform to specific federal changes or as one omnibus
bill to conform to the federal law as of a certain date with
specified exceptions, a so-called "conformity" bill.
The last California-federal conformity bill was enacted in 2005
[AB 115 (Klehs), Chapter 691, Statutes of 2005], and for the
last three years, businesses, tax practitioners and state tax
agencies have been advocating for a new bill to conform state
tax laws to ever-changing federal tax laws. Businesses,
generally, prefer conformity to federal tax laws because it
reduces their state tax compliance costs. The tax
practitioners have argued that there are significant costs
associated with federal non-conformity. Failure to conform to
federal law in some areas may lead to improper tax reporting
to California and extra costs to the taxpayers. As an
example, a taxpayer may roll-over balances in an Archer
Medical Savings Account to a new Health Savings Account
without triggering liability at the federal level, but will
unknowingly face penalties for the transfer since it
constitutes a disqualified distribution for state purposes.
Finally, conformity legislation is also important to state
agencies. Conformity eases the burden, and reduces the costs,
of tax administration because the state may rely on federal
audits, federal case law, and regulations.
While state conformity to federal income tax provisions offers
certain advantages and reduces tax compliance costs, it can
also significantly impact state revenues. Thus, it would be
difficult to achieve complete conformity with federal income
tax rules. Often, the Legislature needs to increase tax rates
to find funding to adopt a new or expand an existing credit or
deduction allowed for federal income tax purposes. Tax
credits, deductions, and exemptions are designed to provide
incentives for taxpayers that incur certain expenses or to
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influence behavior, including business practices and
decisions. Both the Federal and state governments often use
tax policy to influence taxpayers' behavior. However, federal
tax incentives may not necessarily produce the same effect on
the taxpayer's behavior at the state level, if adopted by the
state government, as they do on the federal level.
Furthermore, unlike the Federal government, California cannot
print money to subsidize its budget. Therefore, the
Legislature must be mindful of fiscal effects of conforming to
federal tax laws, even if those may not trigger significant
fiscal concerns in Congress.
In 2008, AB 1561 (Calderon), required a 2/3 vote of the
membership in each house. AB 1561 did not advance from the
Senate Floor because it failed to secure 27 Senate votes.
Last year, the Legislature approved AB 1580 (Calderon), but
the Governor vetoed it because of a "single provision inserted
at the last minute" that he could not support. The
Legislature continues to struggle with tax conformity and SBx8
32 represents the most recent attempt to ease the hardship on
taxpayers and tax practitioners by bringing the two tax codes
closer together.
3)Conformity Decisions . Complete tables of the conformity
decisions implemented by SB 32 x8 may be found in the Senate
Revenue and Taxation Committee's analysis of this bill. Full
descriptions of each of the conformity items in SB 32 x8 are
included in the FTB's annual report to the Legislature,
"Summary of Federal Income Tax Changes," that are available on
the FTB's website.
4)Mortgage Debt Forgiveness . The Legislature approved SB 1055
(Machado), Chapter 282, Statutes of 2008, which provided
modified conformity to the MFDRA for discharge of mortgage
indebtedness in the 2007 and 2008 tax years. Last year,
Senate Revenue and Taxation Committee held SB 97 (Calderon),
which extended modified conformity to discharge of mortgage
indebtedness in the 2009 and 2010 tax years, and this
Committee held AB 111 (Niello), which provided full conformity
to MFDRA. AB 1580, which was vetoed by the Governor in 2009,
would have provided homeowners greater assistance, not only by
extending the mortgage debt forgiveness provisions until
January 1, 2013, but also by increasing the amount of forgiven
mortgage indebtedness excludable from taxpayer's gross income
from $250,000 ($125,000 in the case of a married individual
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filing a separate return) to $500,000 ($250,000 in case of a
married individual filing a separate return). The same
mortgage debt forgiveness provisions are included in SB 32 x8,
tying California law to federal law until 2013. In addition,
SB 32 x8 provides for a retroactive application of those
provisions for cancellation of debt income arising from
mortgage debt forgiveness until the 2012 tax year.
5)Waiver of the early withdrawal penalty for public safety
employees. Existing federal tax law imposes a 10% withdrawal
penalty tax on early distributions made from a qualified
retirement plan to a taxpayer under the age of 59 , unless an
exception applies. For distributions made after August 17,
2006, Section 882 of the PPA of 2006 amended IRC Section 72(t)
to provide an exception from the 10% penalty for distributions
from a governmental defined benefit pension plan to a
qualified public safety employee who separates from service
after the age of 50. The exception applies to distributions
made to public safety employees after December 31, 2006.
Existing federal law also provides tax relief from the penalty
to public safety officers who use distributions received from
governmental plans to pay for health and long-term care
insurance for himself/herself or his/her spouse or dependents
(IRC Section 402, as amended by Section 845 of the PPA).
This exception from the 10% penalty tax applies to
distributions made after December 31, 2006.
Existing state law conforms to federal law, as of January 1,
2005, with respect to taxation of qualified retirement plans,
except that California imposes the early withdrawal penalty at
2 %, rather than 10%. SB 32 x8 provides partial
conformity to federal tax laws by allowing relief from the 2
% penalty for early distributions made to public safety
employees. Due to the nature of their jobs, public safety
employees often retire early, well before age 59 . However,
those retired employees are unable to access all of their
retirement funds without paying the penalty under California
law.
While some federal law changes relating to qualification of
federal plans are automatically incorporated into California
tax laws, specific state legislation in other areas is
required for federal law enacted after the last conformity
date to apply for California tax purposes. Thus, existing
state law provides that federal changes to Part I of
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Subchapter D of Chapter 1 of IRC Sections 401 through 420,
inclusive, relating to pension, profit-sharing, stock bonus
plans, other employee benefit plans, and IRC Section 457,
relating to deferred compensation plans of state and local
governments and tax-exempt organizations, automatically apply
without regard to taxable years to the same extent as
applicable for federal income tax purposes. All federal
changes made to those IRC sections are automatically adopted
by California without regard to the specified date.
Therefore, as of December 31, 2006, California automatically
conformed to the PPA changes to IRC Section 402 relating to
employee benefits plans and already allows public safety
officers to use up to $3,000 of distributions from
governmental plans to pay for qualified health insurance
premiums or qualified long-term care insurance contracts. In
addition, California also conforms to the PPA provision
providing an exclusion from gross income for distributions
from eligible governmental plans to be used to pay qualified
health insurance premiums and long-care costs and, therefore,
no state legislation is needed to conform to that provision.
6)Erroneous Refund Penalty . Recently, Congress decided that on
and after May 25, 2007, taxpayers filing an erroneous claim
for refund should face a penalty equal to 20% of the
disallowed amount of the claim, unless the taxpayer shows a
reasonable basis for the refund. The penalty does not apply
to any part of the disallowed amount of the claim that relates
to the earned income credit or on which the accuracy-related
or fraud penalties are charged. The purpose of penalties is
to encourage voluntary compliance. Taxpayers often take
aggressive tax positions, and with taxpayers petitioning FTB
for hundreds of millions of dollars in refund claims each
year, failing to conform to the erroneous refund penalty may
encourage California taxpayers to continue to make tenuous
refund claims, especially, since the Internal Revenue Service
(IRS) and many other states apply the penalty.
When Congress was debating whether or not to enact the erroneous
refund penalty, the Treasury Assistant Secretary for Tax
Policy, Eric Solomon, was asked to testify regarding the
penalty before the Senate Finance Committee on Ways to Reduce
the Tax Gap in 2007. In his testimony, he explained that,
under current law, the accuracy-related penalty that a
taxpayer might pay, generally, depends on the amount of
underpayment of tax. If a taxpayer wrongfully claims a
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refund, however, there is no penalty as long as no additional
tax liability is attributable to the wrongful claim, as often
happens when there has been over-withholding. Mr. Solomon
stated that "the IRS has observed aggressive behavior that is
undeterred by the tax code's current accuracy-related penalty
framework, which is geared toward deterrence of reported tax
deficiencies. As a practical matter, some taxpayers and their
advisors may be taking advantage of the existing penalty
structure by aggressively claiming credits that generate
refunds, in an effectively risk-free gamble." To address this
problem, the IRS suggested an imposition of a penalty on an
unreasonable claim for refund or credit. As emphasized by Mr.
Solomon, the erroneous refund penalty creates "a parallel
system of deterrence applicable even if the taxpayer is in a
refund, rather than a deficiency, procedural posture, thus
stemming the tide of aggressive claims that are made without
reasonable basis or reasonable cause, regardless of the
procedural context." ("Testimony of Treasury Assistant
Secretary for Tax Policy, Eric Solomon, Before the Senate
Finance Committee on Ways to Reduce the Tax Gap",
http://www.treas.gov/press/releases/hp360.htm ).
SB 32 x8 seeks to implement a similar penalty to deter taxpayers
from filing aggressive claims for refund. Opponents of the
erroneous refund penalty, however, assert that the terms of
the penalty, such as "reasonable basis" and "excessive amount"
are undefined, that the penalty disproportionately punishes
taxpayers compared to the amount of noncompliance, and that no
reasonable cause exception exists, among other arguments. To
alleviate the burden of this penalty on individuals who,
generally, are not sophisticated in complicated tax matters,
SB 32 x8 (similarly to AB 1580 from last year) provides an
exemption for the vast majority of individuals. Thus,
individuals with adjusted gross income of less than $250,000
(in the case of single/married filing jointly taxpayers) or
$125,000 (married filing separately) are not subject to the
erroneous refund penalty under this bill.
7)"Kiddie" Tax . SB 32 x8 would conform to federal law by
increasing the age of minor children for purposes of the
"kiddie" tax. This tax requires unearned income (e.g.,
interest, dividends, etc.) of children under a specified age
to be taxed at the parents' tax rate. The federal law was
initially introduced to address certain practices whereby
wealthy taxpayers would transfer assets like stocks or bonds
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to their children, who usually paid tax at a lower rate. In
2005, the federal law was changed to apply to children under
the age of 18, and in 2007, those rules were changed again to
apply to dependent children under the age of 24.
8)Inflation-indexing of gross income limitations on retirement
savings incentives . For taxable years beginning on or after
January 1, 2007, the PPA indexes the income limits for
Individual Retirement Account (IRA) contributions beginning in
2007. The indexing applies to the income limits for
deductible contributions for active participants in an
employer-sponsored plan,<1> the income limits for deductible
contributions if the individual is not an active participant
but the individual's spouse is, and the income limits for Roth
IRA contributions. Indexed amounts are rounded to the nearest
multiple of $1,000. SB 32 x8 would conform the Personal
Income Tax Law to those provisions.
9)Grants for qualified energy property . Federal law allows a
renewable electricity income tax credit for the production of
electricity from qualified energy resources at qualified
facilities. Qualified energy resources generally include
wind, biomass, solar energy, geothermal energy, small
irrigation power, municipal solid waste, qualified hydropower
production and marine and hydrokinetic renewable energy. To
be eligible for this credit, electricity produced from the
qualified energy resources at qualified facilities must be
sold by the taxpayer to an unrelated person. The production
tax credit for electricity produced from renewable resources
is generally claimed over a 10-year period and is not
refundable.
In addition to the renewable electricity production tax credit,
under federal tax law, a taxpayer is allowed to claim a credit
for the investment in certain property. The investment tax
credit includes an energy credit that is allowed for certain
qualifying energy property placed in service. The qualifying
energy property includes certain fuel cell, solar, geothermal
power production, small wind energy property, combined heat
and power system, and geothermal heat pump property. The
energy credit is generally equal to 30% of the taxpayer's
---------------------------
<1> Under the PPA, for 2007, the lower end of the income phase
out for active participants filing a joint return is $80,000, as
adjusted to reflect inflation.
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basis in qualified fuel cell property, certain solar energy
property, and wind energy property. It is 10% of the
taxpayer's basis in all other types of qualifying energy
property. The investment tax credit may be claimed entirely
in the year the facility is placed in service.
In February of 2009, Congress enacted, and the President signed,
the American Recovery and Reinvestment Act (ARRA), which,
among other things, allows taxpayers to make an irrevocable
election to treat certain qualified property that is part of a
qualified investment credit facility placed in service in 2009
through 2013 as energy property eligible for a 30% investment
credit. The investment tax credit option may be attractive
to tax investors that are not sure of their tax liability in
the future (the 10-year period). Furthermore, the ARRA
authorizes the Secretary of Treasury to provide a grant to
each person who places in service during 2009 or 2010 energy
property that is either (a) an electricity production facility
otherwise eligible for the renewable electricity production
credit, or (b) qualifying property otherwise eligible for the
energy investment tax credit. The grant amount equals to up
to 30% the basis of the qualified property. In other words, a
taxpayer that elects to receive the investment tax credit can
also elect to receive a 30% grant rather than the 30% tax
credit. The ability to receive the credit or grant in the
year in which property is placed in service helps owners to
finance the project.
Congress excluded the grant proceeds from a taxpayer's income
but required that the basis of the property be reduced by 50%
of the amount of the grant. In addition, some or all of each
grant is subject to recapture if the grant eligible property
is disposed of by the grant recipient within five years of
being placed in service. The provision also permits
taxpayers to claim the credit with respect to otherwise
eligible property that is not placed in service in 2009 and
2010 so long as construction begins in either of those years
and is completed prior to 2013 (in the case of wind facility
property), 2014 (in the case of other renewable power facility
property eligible for credit under IRC Section 45), or 2017
(in the case of any specified energy property described in IRC
Section 48). Under the program, if a grant is paid, no
renewable electricity credit or energy credit may be claimed
with respect to the grant eligible property.
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The grant program was created to help developers of renewable
energy projects to finance these projects. Often, developers
seek investors that are usually allocated 99% of the income,
gains, losses, deductions and tax credits of the project.
However, in the current economic environment the potential
investors may not have enough tax liability to utilize those
deductions and credits. The creation of the grant program
allows developers to receive a federal subsidy to continue
with the renewable energy projects. Committee staff notes,
however, that it is unclear how a grant paid after the project
is placed in service, i.e. after it is completed, helps
taxpayer with obtaining financing for the project, given the
current state of the financial markets.
In absence of an authorized statute, taxpayers must include the
grant proceeds as income for state purposes. SB 32 x8
excludes these grants from income because an unexpected tax
could cause project developers to terminate or delay the
projects, causing job losses and less renewable power for the
state. SB 32 x8 also conforms to federal law by excluding
these grants from taxpayer's income, requiring the 50% basis
adjustment, and incorporating the recapture provisions of
Section 1603(f) of the ARRA.
10)Proposed Technical Amendments . The FTB's staff suggests the
following technical amendments to SB 32 x8.
AMENDMENT 1
On page 23, line 33, strike out "50(a)", and insert:
AMENDMENT 2
On page 23, line 34, after "Code, and", strike out "increased by
any recapture provided," and insert:
adjusted in accordance with rule applied
AMENDMENT 3
On page 25, line 3, strike out "events," and insert:
event
AMENDMENT 4
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On page 83, line 34, strike out "50(a)", and insert:
48(a)
AMENDMENT 5
On page 83, line 35, after "Code, and", strike out "increased by
any recapture provided", and insert:
adjusted in accordance with rules applied
AMENDMENT 6
On page 107, line 21, strike out "events", and insert:
event
AMENDMENT 7
On page 107, line 22, strike out "April 6, 2007", and insert:
April 16, 2007
REGISTERED SUPPORT / OPPOSITION :
Support
California Federation of Teachers
California Wind Energy Association
Center for Responsible Lending
Service Employees International Union
Solar Alliance
Opposition
California Bankers Association
California Chamber of Commerce
California Taxpayers' Association
California Manufacturing and Technology Association
Tech America
Western States Petroleum Association
Analysis Prepared by : Oksana Jaffe / REV. & TAX. / (916)
319-2098
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