BILL ANALYSIS Ó
AB 2372
Page A
Date of Hearing: May 13, 2014
ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
Raul Bocanegra, Chair
AB 2372 (Ammiano) - As Amended: April 1, 2014
2/3 vote. Tax levy. Fiscal committee.
SUBJECT : Property taxation: change in ownership.
SUMMARY : Revises the circumstances under which a "change in
ownership" of real property owned by a legal entity is deemed to
have occurred. Specifically, this bill :
1)Contains legislative findings and declarations regarding the
existing system for determining a "change in ownership" for
the purpose of commercial property assessment.
2)Provides that, when 100% of ownership interests in a legal
entity are sold or transferred in a single transaction, the
purchase or transfer of those interests is considered to be a
"change of ownership" of the real property owned by the
entity, thus, triggering a reassessment of the property for
tax purposes.
3)Specifies that a "purchase or transfer" of ownership interests
in a legal entity means a merger, acquisition, private equity
buyout, transfer of partnership shares, or any other means by
which a legal entity acquires the ownership interests of
another legal entity, including the subsidiaries or affiliates
of the legal entity and the property owned by those
subsidiaries and affiliates.
4)States that a purchase or transfer of 100% of ownership
interests in a legal entity is considered to be a "change of
ownership" of the real property owned by that entity, whether
or not any one legal entity that is a party to the transaction
acquires more than 50% of the ownership interests.
5)Requires the State Board of Equalization (BOE) to notify
assessors when such a change in ownership has occurred.
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6)Defines the phrase "single transaction" as a transaction in
which 100% of the ownership interests are sold or transferred
in either one calendar year or within a three-year period
beginning on the date of the original transaction when any
percentage of ownership interests are sold or transferred.
7)Defines the term "legal entity" as a corporation, a
partnership, a limited liability company, or other legal
entity.
8)Defines the phrase "ownership interests" as corporate voting
stock, partnership capital and profits interests, limited
liability company membership interests, and other ownership
interests in legal entities.
9)Requires persons acquiring ownership interests in a legal
entity to record a deed with the county recorder and report
the acquisition to the BOE.
10)Requires legal entities to report original co-owners interest
changes to the assessor.
11)Requires the BOE to prescribe regulations that may be
necessary to carry out the purposes of this bill.
12)Increases the penalty for failure to file a change in
ownership statement with the BOE from 10% to 20%.
13)Takes effect immediately as a tax levy.
EXISTING LAW :
1)Provides that all property is taxable, unless otherwise
provided by the California Constitution or federal laws.
(Section 1(a), Article XIII, California Constitution.) Limits
ad valorem taxes on real property to 1% of the full cash value
of that property (Proposition 13).
2)Requires real property to be reassessed to its current fair
market value whenever a "change in ownership" occurs.
(California Constitution, Article XIII A, Section 2; Revenue
and Taxation Code (R&TC) Sections 60 - 69.5.)
3)Provides that "change in ownership" includes a transfer of any
interest in real property between a corporation, partnership,
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or other legal entity and a shareholder, partner or any other
person. (R&TC Section 61(j).)
4)Specifies in RT&C Sections 60 through 69.5 what constitutes "a
change in ownership." Sets forth the general rule that, when
real property is owned by a legal entity, the purchase or
transfer of ownership interests in that entity does not
trigger a change in ownership of the property, unless a) there
is a "change in control" of the legal entity, or b) a
cumulative transfer of more than 50% by the "original
co-owners." (R&TC Section 64.) Thus, when any person or
entity obtains control, through direct or indirect ownership
or control, of more than 50% of the voting stock of a
corporation, or a majority ownership interest in any other
type of legal entity, a reassessment of real property owned by
the acquired legal entity (or any of its subsidiaries) is
triggered. (R&TC Section 64(c)(1)(A).) Furthermore, when
voting stock or other ownership interests representing
cumulatively more than 50% of the total interest in a legal
entity is transferred by any of the "original co-owners" in
one or more transactions, the real property that was
previously excluded from reappraisal will be reassessed.
[R&TC Section 64(d)].
5)Requires legal entities to file a change in ownership
statement (LEOP COS) with the BOE within 90 days of a change
in control or change in ownership under R&TC Section 64(c) or
(d). In the case of a change in control under R&TC Section
64(c), the person or legal entity that acquired control is
responsible for filing the LEOP COS.
6)Imposes a 10% tax penalty, applicable to the new base year
value reflecting a change in ownership, on legal entities that
fail to file a change in ownership statement with the BOE.
7)States that, generally, when real property is owned by a
homeowner, the purchase or transfer or ownership interests in
that entity triggers a change in ownership of the property.
However, specific exemptions from reassessment are provided
for intra-family transfers, replacement residences of senior
citizens and disabled persons, and specific types of home
improvements.
8)Requires business personal property to be reassessed annually
at its current market value. Personal property owned by a
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homeowner is not generally subject to property taxation.
FISCAL EFFECT : The BOE estimates that the annual property tax
revenue increase associated with the new "change of ownership"
rule is approximately $73 million per year. However, BOE
acknowledged that estimating the revenue increase with any
degree of certainty is difficult.
COMMENTS :
1)Arguments in Opposition . Opponents state:
Currently, under Proposition 13, commercial property is
reassessed only when there is an actual change of ownership
in the entity that owns the property. That is, another
entity or person has acquired at least 50% of the ownership
interest of the entity that owns that property and
therefore has a controlling interest in the property. This
is the most common-sense interpretation of Proposition 13's
requirements. It creates a bright line to determine when
property ownership has changed, and it is consistent with
the underlying purpose of Proposition 13, which intended to
provide property owners certainty and stability about the
amount of property taxes due - on sale and thereafter.
AB 2372 would drastically alter the definition of "change
of ownership" under Proposition 13 by dictating that a
"change of ownership" occurs whenever 100% of the ownership
interests in the legal entity that owns the commercial
property are sold within a three-year period, regardless of
whether any person or entity actually obtains control
through direct or indirect ownership of at least 50% of the
voting stock or ownership interest in the entity owning the
property. This new definition, which merely focuses on
ownership rather than control, will subject commercial
property, especially property held by publicly traded
corporations, to continuing reassessment that will at some
point result in higher property taxes - the obvious intent
of this legislation. However, given that a reassessment
could be triggered under this definition on a daily,
weekly, or even monthly basis, the anticipated revenue gain
by AB 2372 will be obsolete, as the market value of
commercial property does not change within such a short
time frame. Thereby, AB 2372 will result in becoming a
tool for harassing owners of commercial property with
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constant reassessments, and an overwhelming workload for
county assessors.
The ultimate effect of increasing property taxes for
commercial property will keep detrimental impacts on the
general public, including small businesses, apartment
residents, employees, and consumers. Any higher taxes
imposed on companies who own commercial property will
likely be passed on to the tenants of such property through
higher rent, including businesses and individuals who rent
apartments in which to live. Such increased costs will
continue to be passed onto others, including potential
reduction of employee benefits, reduction of workforce, or
even higher prices for consumers.
Moreover, with the proposed definition of "change of
ownership" under AB 2372, it will trigger reporting
requirements for multiple "owners" of these entities.
Despite the percentage of ownership an individual or entity
acquires in a company, they will be required to report this
change in ownership or face a penalty up to 20% of the
assessed fair market value of the commercial property. A
penalty for failure to file a statement is imposed even if
the county assessor ultimately determines no "change of
ownership" has occurred. This duplicative and onerous
reporting requirement that AB 2372 seeks to impose creates
a potentially unfair monetary trap for a minority owner in
a company that is unaware that a 100% change of ownership
within the prior three years has even taken place."
Opponents also state that, "The idea of a split-roll
property tax has been fully vetted and consistently
rejected since the passage of Proposition 13 in 1978.
While some believe that a split roll would raise revenue,
it would, in fact, stifle the state's economic growth in
the long term. From what is known about the economic
impacts of split roll, it remains an ill-advised idea."
Furthermore, the opponents argue that Proposition 13 does
not shift the property tax burden to homeowners and, in
fact, "Proposition 13 has prevented a property tax shift to
homeowners."
2)Background: Proposition 13 and "Change in Ownership" . The
property tax applies to all classes of property and is one of
the major general revenue sources for local governments in
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California. It is imposed on the property owners and is based
on the value of the property. Much of the law pertaining to
taxation of property is prescribed by the California
Constitution, Article XIII and Article XIII A. Since the
adoption of Proposition 13 in 1978, real property has,
generally, been taxed based on its value at the time of its
acquisition, with increases for inflation limited to 2% per
year. The property is reassessed to its market value when the
ownership of property is changed. While the requirement to
reassess property upon a change in ownership is contained in
the California Constitution, the phrase "change in ownership"
is not defined.
Shortly after the passage of Proposition 13, this Committee
appointed a special Task Force - a broad-based, 35-member
panel that included legislative and BOE staff, county
assessors, attorneys in the public and private sectors, and
trade associations - to recommend the statutory implementation
for Proposition 13, including the "change in ownership"
provisions. With respect to a transfer of ownership interest
in a legal entity that owns real property, the Task Force
initially recommended adopting the "separate entity" theory
that respects the separate identity of the legal entity.
According to this theory, so long as the legal entity owned
the property, the property will not be reassessed, even if
most or all of the ownership interests in the entity, i.e.
stock or partnership interests, had been transferred. The
Task Force recommended the "separate entity" approach because
of the perceived administrative and enforcements problems with
disregarding the separate identity of a legal entity and the
unpredictable ripple effects of ignoring the general separate
entity laws.
However, the "majority-takeover-of-corporate stock" provision
was subsequently added "out of a concern that, given the lower
turnover rate of corporate property, mergers or other transfer
of majority controlling ownership should result in a
reappraisal of the corporation's property - an effort to
maintain some parity with the increasing relative tax burden
of residential property statewide, due to more rapid turnover
of homes." (Implementation of Proposition 13, Volume 1,
Property Tax Assessment, a report prepared by the Assembly
Revenue and Taxation Committee, California State Assembly
Publication 748, October 29, 1979). Thus, the law was amended
to provide that whenever any person or entity has purchased or
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otherwise acquired more than 50% ownership of a corporation or
other legal entity, any real property owned by the acquired
entity must be reappraised to full market value.
It should be noted that while the Task Force, in order to
mitigate administrative difficulties, recommended the
"separate entity" approach for determining when a change in
ownership of real property occurs, it was concerned with the
fact that commercial and industrial properties change
ownership less frequently than residential property and
proposed that the Legislature study the idea of a
constitutional amendment to appraise commercial and industrial
property periodically at current market value.
3)Is There a Problem With the Existing "Change of Ownership"
Definition ? The current system provides property owners with
several ways to structure "change in ownership" transactions
to avoid paying higher property taxes and allows purchasers to
avoid reassessment even if 100% of a company changes hands. A
business may avoid a reappraisal of the property of an
acquired entity by simply structuring the acquisition in a way
that prevents any of the separate purchasers from receiving
more than 50% ownership in the acquired entity. Thus, if
multiple individuals or entities acquire another entity, in a
single transaction, but none of the purchasers acquires more
than 50% interest in the entity, a reappraisal of the property
is not required.
The statutory provisions implementing Proposition 13 were
intended to ensure that when an entity or person acquires a
business entity, a reassessment of the acquired entity's real
property is triggered, especially in cases when 100% of
ownership has changed. The point of the Task Force, in its
role of finding the appropriate rule for a "change in
ownership," was to implement a statutory scheme that best
represented the public intent when it voted for Proposition
13. The idea of enabling a 100% change in ownership by
multiple affiliated purchasers, each of which has acquired
less than a 50% ownership interest, to completely avoid a
reappraisal of the corporation's underlying property is
probably not what the voters were contemplating when they
passed Proposition 13. As noted by the Task Force, the
initial recommendation for using a "separate entity" approach
was due to the perceived administrative and enforcement
problems, not necessarily because it best represented the will
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of the voters. With 35 years of experience, it seems
appropriate to look again at the rules for "change of
ownership."
4)What is a "Split Roll" ? The phrase "split roll" generally
refers to a system of taxation where various types of real
property are taxed according to different standards or at
different tax rates. The "split" is typically proposed
between residential property (or the subset of owner-occupied
homes) and all other property types. This phrase is often
used to describe any legislation attempting to redefine
"change in ownership" as it applies to the purchase or
transfer of ownership interests in legal entities (i.e., stock
or ownership shares in a corporation or partnership) that own
real property in a way that would trigger more frequent
reassessments to current market value levels. Although the
phrase is used to describe proposed amendments to the "change
in ownership" rule, it is not truly a "split roll" as it is
more generally understood because commercial property, under
the provisions of this measure, will not be taxed according to
a different set of standards, i.e., market-value assessment or
a different tax rate. A true "split roll" - a different tax
rate or value standard - is not possible without a
constitutional amendment.
5)Market vs. Assessed Value . Since property values increase, on
average, at a faster rate than 2% a year, the current assessed
value of property in California is presumed to be lower than
its market value. However, determining the exact disparity
between the assessed and market value of commercial property
in California is difficult to accomplish. Cities and counties
vary widely in terms of development. An older and more
established city may have a large number of commercial
properties with the original base year rate of 1975, creating
a large disparity between the assessed and market value of
property. On the other hand, a newer city with recent
development may have a smaller disparity among commercial
properties. For example, the median disparity ratio for
non-modified properties in Los Angeles County was 4.0 in
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2002.<1> [Sexton, Terri A. and Sheffrin, Steven M, The Market
Value of Commercial Real Property in Los Angeles County 2002.
California Policy Research Center for the Senate Office of
Research, (2003).] Additionally, Los Angeles County has an
assessed commercial property value of $147 billion and an
estimated market value of $231 billion. (Id.)
What does this mean? First, it means that there is in fact a
disparity between assessed and market value properties and, if
closed, could lead to additional property tax revenue.
Second, disparity ratios provide a glimpse into the magnitude
of market inefficiencies in our acquisition valuation system.
As explained later, the acquisition value system creates
moving penalties, barriers to entry, and increases the price
of purchasing property. However, even if all properties are
suddenly assessed at their current market value, these
inefficiencies will persist because annual assessments are
based on the date of acquisition.
6)Proposition 13: Market Inefficiencies . The acquisition value
system causes a number of economic inefficiencies.
Specifically, it increases the cost of purchasing property,
---------------------------
<1>Professor Terri Sexton has attempted to quantify the
disparity between assessed value and market value of commercial
properties in Los Angeles County. She provides disparity
ratios, which are defined as the ratio of market to assessed
value, for non-modified and modified commercial and industrial
properties. The median disparity ratio for non-modified
properties is 4.0. A disparity ratio of 4.0 means that the
actual market value of non-modified properties that have not
changed ownership since 1975 is roughly four times higher than
their assessed value for tax purposes. Non-modified properties
with a 1975 base year have a total assessed value on the 2001-02
roll of $9.37 billion. Applying the disparity ratio of 4.0 to
these properties produces a market value of $37.45 billion. All
together, the report found that Los Angeles County has an
assessed value of $147 billion and an estimated market value of
$231 billion. The disparity ratio is not constant and that the
number of properties with a 1975 base year rate has declined
since the enactment of Proposition 13. The percentage of
commercial properties with the 1975 base year value was 36% in
1991, 29% in 1996, and 18% in 2002. Additionally, the report
found that 40% of the additional property tax revenue, if all
properties were reassessed at market value, would come from 1975
base year properties.
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imposes moving penalties, and creates barriers to entry.
a) Capitalization of Property . To a certain degree, the
tax benefits provided by Proposition 13 are capitalized
into the market values of property. Capitalization occurs
when the costs of acquiring an asset are included into the
price of the asset. Proposition 13 has increased the
amount that potential buyers are willing to pay for a
property. [Sexton, Terri A. and Sheffrin, Steven M, and
O'Sullivan, Arthur, Proposition 13: Unintended Effects and
Feasible Reform. National Tax Journal, 52.1 (1999).] In
general, a decrease in the property tax rate increases the
net benefit of owning property. Although the study focuses
on residential property, the rule also applies to
commercial real estate. Since owning the property for a
long period of time maximizes the net benefit of
Proposition 13, those that change ownership less frequently
will be most likely to pay more for the property. Those
that purchase and sell property more frequently may be
discouraged or pushed out of the market by higher bidders.
As Professor Sexton noted, "the winners will be those with
the lowest turnover rates and the losers will be those with
the highest turnover rates." (Id.)
b) Moving Penalty . In addition to increasing the cost of
purchasing property, the acquisition value system penalizes
commercial property owners when they move from one location
to another. If the market values of the surrounding
properties increase at a rate higher than 2% per year, a
gap begins to form between the assessed and market values
of property. As a result, a property owner faces a
significant increase in property taxes when he/she
purchases a property in a new location. The moving penalty
may make a business less responsive to changes in business
and market conditions. (Id.) A business owner may decide
to tolerate changes in the market; even if the business is
able to keep its customer base, it may become more
difficult for the business to remain competitive.
c) Barriers to Entry . One of the most significant issues
with Proposition 13's acquisition value system is that it
creates a barrier to entry for new businesses. If a new
business moves next door to an existing competitor and
purchases an identical building, the new business will pay
higher property taxes because its property will be assessed
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at the current market value. The difference between what
the two businesses pay in property tax will vary, but it
will be an additional expense that the new business will
have to include in the costs of production.<2>
7)The Proposed Solution. As discussed, properties owned by
legal entities are taxed under a "separate entity" theory,
which means that, as long as the property is owned by the same
legal entity, that property would not be reassessed, even if
most or all of the ownership interests in the entity (i.e.,
stock in the corporation, partners in the partnership) had
changed ownership. According to the author, this bill is
designed to close this obvious and egregious loophole in the
law by providing that, when 100% of ownership interests in a
legal entity holding real property are sold or transferred in
a single transaction, the property must be reassessed, no
matter how many purchasers take ownership of the entity and
regardless of whether any one legal entity acquires more than
50% of the ownership interest. Under current law, only if a
particular transaction results in a change in control of a
legal entity (i.e. one legal entity or individual acquires
more than half of the ownership interest in the legal entity)
would the property owned by that legal entity be subject to
reassessment.
8)The Potential Impact of AB 2372 . As noted by the BOE's
analysis, it is difficult to estimate the number of
transactions that will be subject to reassessment if the
provision of AB 2372 were to be enacted. However, it is clear
that this bill would likely lead to more frequent assessment
of property. The benefits of more frequent assessments are
increased property tax revenues and potentially a reduction in
the disparity ratio among commercial properties. However, the
imposition of a "split roll" may create a number of economic
problems.
--------------------------
<2> For example, Company A has held the same commercial property
since 1975 and pays $10,000 per year in property taxes. If
Company B purchases a similar property next door, it will be
assessed at the current market value. Assuming that market
values have increased an average of more than 2% per year and
assuming both properties are identical, if the property is
purchased at $3 million (its market value), Company B will be
paying $30,000 in property taxes. All else being equal, the
cost of doing business will be higher for Company B.
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According to a 2005 report by Pepperdine University, An
Analysis of Split Roll Property Tax Issues and Impacts, a
split roll proposal in California would do all of the
following: a) increase property taxes by an estimated $6
billion, b) cost the California economy $71.8 billion in lost
output and 396,345 jobs, c) result in increased instability
for local government finances, and d) would further undermine
the attractiveness of the business climate in California.
Additionally, a switch to market valuation taxation would
create upward pressure on rents.<3> It is true that
increasing property taxes on commercial properties will add to
the cost of production and may have a serious impact on
business decisions, e.g., hiring personnel, expanding
operations, creating a new line of products. However, the
Pepperdine University report assumes that no measure will be
implemented to mitigate the impact of a split roll proposal.
Several actions can be taken to mitigate the impact of a
split-roll proposal. As noted in this Committee's
informational hearing on April 8, 2013, Proposition 13 and
Local Taxes, by Professor Terri Sexton, Professor Kirk Stark,
and Legislative Analyst's Office's (LAO) Policy Analyst, Chas
Alamo, the impact of a split roll proposal can be mitigated by
providing tax credits to low-income tenants and small
businesses. Additionally, a "split roll" proposal can be made
revenue neutral by reducing the tax rate below 1%.
9)"Original transaction ." As noted by BOE staff in its analysis
of this bill, identifying the date of the original transaction
is necessary when a rolling three-year period must be tracked.
The author may wish to amend this bill to define the term
"original transaction."
10)Avoiding confusion . The BOE staff also noted that it is
unclear whether R&TC Section 64(c)(1)(B) or R&TC Section 64(d)
would apply for purposes of determining which property is
subject to a reassessment, when a change in occurs under both
of those sections. Thus, if a reassessment is made pursuant
to R&TC Section 64(d), then only the property owned by the
legal entity that was previously excluded under R&TC Section
62(a)(2) is reassessed. If, however, the reassessment is made
pursuant to R&TC Section 64(c)(1)(B), then all property owned
by that legal entity will be reassessed. The author may wish
---------------------------
<3> Proposition 13: Unintended Effects and Feasible Reform. at
110.
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to amend this bill to clarify the order of priority.
11)Notification Requirement. As explained by BOE staff,
assessors discover changes in ownership of real property via
grant deeds or other documents that are recorded with the
county recorder. In addition, the county recorder must
provide the assessor with a copy of the transfer of ownership
document as soon as possible. However, no grant deed or other
document is recorded when a change in ownership of a legal
entity occurs, even if it triggers reassessment of underlying
real property. The BOE monitors changes in ownership and
changes in control of legal entities via the Legal Entity
Ownership Program (LEOP) and helps assessors discover
unreported changes. But, ultimately, assessors depend on
legal entities to self-report these types of changes of
ownership.
Existing law requires a legal entity to file a change in
ownership statement with BOE within 90 days of whenever a
change in control or a change in ownership of a legal entity
occurs. If a legal entity fails to report and the failure is
discovered later on, then an escape assessment will be made
for every tax year that the entity failed to file the change
in ownership statement. There is no statute of limitations
that would apply to those escape assessments. The penalty for
failure to file a change in ownership statement upon written
request by the BOE is 10% of the new base year value resulting
from the transfer, or 10% of the current year's taxes on that
property if no change in control or change in ownership
occurred.
The provision in this bill would strengthen reporting
requirements by requiring the BOE to notify assessors if a
change in ownership occurs. Additionally, persons acquiring
an ownership interest in a legal entity must report the
acquisition to the BOE and file a deed with the county
recorder. Provisions also require a legal entity to report
any changes of the original co-owner interest to the assessor.
Finally, this bill would increase the penalty for a person or
legal entity that does not file a change in ownership
statement. Since assessors rely heavily on self-reporting
measures, these additional requirements may help the BOE and
county assessors discover changes in ownership that may
otherwise go unnoticed. The requirement to file a deed with
the county recorder will also notify the public of a change in
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ownership.
12)Similar Legislation . The BOE notes that in recent years
numerous bills have been introduced to require annual
reassessment of nonresidential property to its current market
value via constitutional amendment, increase the tax rate on
nonresidential property, or modify the change in ownership
definitions for legal entities (which generally own
nonresidential property). For a comprehensive list of the
previous bills, please refer to the BOE analysis of this bill.
REGISTERED SUPPORT / OPPOSITION :
Support
None on file
Opposition
Air Conditioning Trade Association
Air Logistics Corporation
American Coating Association
American Resort Development Association
Apartment Association
Apartment Association of Greater Los Angeles
Apartment Association, California Southern Cities
Associated General Contractors of California
BIOCOM
Boston Properties
Building Owners and Managers Association of California
California Apartment Association
California Association of Boutique & Breakfast Inns
California Association of Realtors
California Attractions and Parks Association
California Bankers Association
California Beer and Beverage Distributors
California Building Industry Association
California Business Properties Association
California Chamber of Commerce
California Grocers Association
California Healthcare Institute
California Hotel & Lodging Association
California Manufacturers & Technology Association
California Mortgage Bankers Association
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California New Car Dealer Association
California Railroad Industry
California Restaurant Association
California Retailers Association
California Tank Lines, Inc.
California Taxpayers Association
California Travel Association
Camarillo Chamber of Commerce
Chambers of Commerce Alliance, Venture & Santa Barbara Counties
Chemical Transfer Company, Inc.
Construction Employers' Association
Contra Costa Taxpayers Association
Council of State Taxation
East Bay Rental Housing Association
EastGroup Properties, Inc.
Family Winemakers Association
General Growth Properties
Greater San Fernando Valley Chamber of Commerce
Howard Jarvis Taxpayers Association
International Council of Shopping Centers
LTC Properties, Inc.
NAIOP of California, the Commercial Real Estate Development
Association
National Federation of Independent Business
NOR CAL Rental Property Association
Orange County Business Council
Orange County Taxpayers Association
Pacific Life Insurance Co.
Plumbing-Heating-Cooling Contractors Association of California
San Diego County Apartment Association
San Francisco Chamber of Commerce
San Jose Silicon Valley Chamber of Commerce
Santa Barbara Rental Property Association
Small Business Action Committee
Sunstone Hotel Investors, Inc.
Superior Tank Wash Inc.
Silicon Valley Leadership Group
TechAmerica
West Coast Leasing, LLC
West Coast Lumber & Building Material Association
Western Electrical Contractors Association
Western Growers Association
Western States Petroleum Association
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Analysis Prepared by : Oksana Jaffe / REV. & TAX. / (916)
319-2098