BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                    AB 1559


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          CONCURRENCE IN SENATE AMENDMENTS


          AB  
          1559 (Dodd)


          As Amended  August 8, 2016


          2/3 vote  Urgency


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          |ASSEMBLY:  |79-0  |(May 5, 2016)  |SENATE: |38-0  |(August 15,      |
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          Original Committee Reference:  REV. & TAX.


          SUMMARY:  Authorizes the State Board of Equalization (BOE), in  
          the case of a disaster, to extend the time for making any report  
          or return or paying any tax for a period of up to three months.


          The Senate amendments:


          1)Delete the provisions allowing an extension for economic  
            disasters.


          2)Remove the references to "natural" disasters and instead  
            specifically define a "disaster" as a fire, flood, storm,  
            tidal wave, earthquake, or similar public calamity, whether or  
            not resulting from natural causes.  










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          3)Add coauthors.    


          EXISTING LAW:  


          1)Authorizes the BOE for good cause to extend the time, not to  
            exceed one month, for a taxpayer to submit any return or pay  
            any amount required to be paid, as specified.  The extension  
            may be granted at any time provided a request therefor is  
            filed with the BOE within or prior to the period for which the  
            extension may be granted.  


          2)Requires any person granted extension relief to pay, in  
            addition to the underlying tax or fee amount, interest at the  
            modified adjusted rate per month, or fraction thereof, from  
            the date on which the payment would have been due without the  
            extension until the date of actual payment.  


          3)Provides similar authority under the following  
            BOE-administered laws:


             a)   The Sales and Use Tax (SUT) Law;


             b)   The Motor Vehicle Fuel Tax Law;


             c)   The Use Fuel Tax Law;


             d)   The Cigarette and Tobacco Products Tax Law;


             e)   The Alcoholic Beverage Tax Law;


             f)   The Timber Yield Tax Law;









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             g)   The Energy Resources Surcharge Law;


             h)   The Emergency Telephone Users Surcharge Act;


             i)   The Hazardous Substances Tax Law;


             j)   The Integrated Waste Management Fee Law;


             aa)  The Oil Spill Response, Prevention, and Administration  
               Fees Law;


             bb)  The Underground Storage Tank Maintenance Fee Law;


             cc)  The Fee Collection Procedures Law; and, 


             dd)  The Diesel Fuel Tax Law.


          4)Authorizes, in the case of a disaster, specified interest  
            relief for late payments and returns under the SUT Law.   
            Specifically, if the BOE finds that a person's failure to make  
            a timely return or payment was due to a disaster, and occurred  
            notwithstanding the exercise of ordinary care and the absence  
            of willful neglect, the person may be relieved of interest.   
            Any person seeking such relief must file with the BOE a  
            statement under penalty of perjury setting forth the facts  
            upon which the claim for relief is based.


          5)Authorizes specified penalty relief for late payments and  
            returns under the SUT Law.  Specifically, if the BOE finds  
            that a person's failure to make a timely return or payment is  
            due to reasonable cause and circumstances beyond the person's  
            control, and occurred notwithstanding the exercise of ordinary  








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            care and the absence of willful neglect, the person shall be  
            relieved of penalties.  Any person seeking such relief must  
            file with the BOE a statement under penalty of perjury setting  
            forth the facts upon which the claim for relief is based.  


          6)Authorizes the Governor to proclaim a state of emergency under  
            specified circumstances.  Specifically, the Governor is  
            empowered to proclaim a state of emergency upon the existence  
            of conditions of disaster or of extreme peril to the safety of  
            persons and property within the state, as specified.


          AS PASSED BY THE ASSEMBLY, this bill:


          1)Authorized the BOE, in the case of a natural or economic  
            disaster, to extend the time for making any report or return  
            or paying any tax for a period of up to three months.


          2)Provided that the extension may be granted at any time  
            provided a request therefor is filed with the BOE within or  
            before the period for which the extension may be granted.


          3)Required any person granted a disaster extension to pay, in  
            addition to the tax or fee amount, interest at the modified  
            adjusted rate per month, or fraction thereof, from the date on  
            which the payment would have been due without the extension to  
            the date of actual payment.  


          4)Took immediate effect as an urgency measure.


          FISCAL EFFECT:  Unknown


          










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          COMMENTS:  


          1)The author has provided the following statement in support of  
            this bill:


               Under limited circumstances, individuals and businesses are  
               permitted to defer state and local taxes and fees to assist  
               them in recovering from a disaster such as a wildfire.   
               Temporary relief from paying taxes and fees helps those  
               individuals and businesses focus their limited resources  
               where they are needed most - to restore their livelihood.   
               However, the one month deferral allowed under current law  
               is not much more than tinkering on the impacted taxpayer's  
               financial margins[.]  


               AB 1559 is an urgency bill, which revises current law by  
               changing the one month deferral for paying of specified  
               fees and taxes per filing period, to three months per  
               filing period in the case of a [...] disaster.  This would  
               grant disaster impacted taxpayers a more significant and  
               meaningful amount of time to restore their business  
               activities and get back on their feet.  


          2)Committee Staff Comments


             a)   A general overview of current law:  Under the SUT Law,  
               taxpayers must file a SUT return on or before the last day  
               of the month following the end of the reporting period.   
               Businesses that are late in paying their tax obligations  
               must pay a 10% penalty, plus interest on the unpaid tax  
               from the tax due date to the date of payment.  One-month's  
               interest is due for each month or fraction of a month that  
               payment is late.  Similar statutory regimes govern the  
               other BOE-administered tax and fee programs. 


             b)   The BOE's existing one-month extension authority:   








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               Existing law allows the BOE for good cause to extend for up  
               to one month the time for making any return or paying the  
               tax due.  Such an extension may be granted at any time  
               provided the request is filed with the BOE within or prior  
               to the period for which the extension may be granted.  An  
               extension provides the taxpayer additional time to file a  
               return and pay the tax, and relieves the person of any late  
               payment penalty.  The law, however, continues to impose  
               interest from the due date until the payment date, except  
               in the case of a disaster.


             c)   The BOE's existing authority to grant interest and  
               penalty relief in specified circumstances:  Existing law  
               authorizes, in the case of a disaster, interest relief for  
               late payments.  Specifically, if the BOE finds that a  
               person's failure to make a timely return or payment was due  
               to a disaster, and occurred notwithstanding the exercise of  
               ordinary care and the absence of willful neglect, a  
               taxpayer may be relieved of interest.  Taxpayers seeking  
               interest relief, however, must file a statement with the  
               BOE under penalty of perjury setting forth the facts upon  
               which the request is based.  


               Likewise, existing law authorizes taxpayers (including  
               those impacted by a disaster) to seek penalty relief.   
               Again, if the BOE finds that a person's failure to make a  
               timely return or payment is due to reasonable cause and  
               circumstances beyond the person's control, and occurred  
               notwithstanding the exercise of ordinary care and the  
               absence of willful neglect, the person shall be relieved of  
               penalties.  Taxpayers seeking penalty relief must also file  
               a statement with the BOE under penalty of perjury setting  
               forth the facts upon which the request is based.  


             d)   What would this bill do?  This bill would authorize the  
               BOE, in the case of a disaster, to extend the time for  
               making any report or return or paying any tax for a period  
               of up to three months.  This bill was introduced in the  
               wake of the Butte and Valley Fires, which devastated  








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               portions of northern California in September 2015.  


             e)   Looking forward:  The author notes that this bill is  
               part of a broader effort to support Lake County and the  
               victims of the Valley Fire.  It should be noted however  
               that, given its prospective application, this bill is  
               likely to afford relief to victims of future disasters in  
               California.  Specifically, the Valley Fire occurred in  
               September 2015, or the third quarter of 2015 for SUT  
               purposes.  Thus, SUT returns for that period were due on  
               October 31, 2015 (or November 30, 2015, assuming a  
               one-month extension was sought).  Applying this bill's  
               proposed three-month extension to victims of the Valley  
               Fire would only bring the filing and payment deadline to  
               January 31, 2016.  Thus, while this bill is unlikely to  
               provide relief to victims of the Valley and Butte Fires, it  
               may provide meaningful relief to victims of future  
               disasters.  


             f)   What is a" disaster"?  As passed by the Assembly, this  
               bill authorized the BOE to provide extension relief in the  
               case of natural and economic disasters, without  
               specifically defining those terms.  The Senate amendments,  
               however, delete the authority to provide relief in  
               connection with economic disasters.  In addition, the  
               Senate amendments delete the term "natural disaster" and  
               instead provide a specific definition of the term  
               "disaster" that conforms to existing BOE regulations.  


          Analysis Prepared by:                                             
                          M. David Ruff / REV. & TAX. / (916) 319-2098   
          FN:  0003937















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