BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 41
                                                                  Page  1


           (Without Reference to File)
           
          SENATE THIRD READING
          SB 41 (Battin)
          As Amended January 29, 2007
          Majority vote.  Tax levy

           SENATE VOTE  :36-0  
           
           REVENUE & TAXATION  8-0         APPROPRIATIONS      16-0        
                                                  
           ----------------------------------------------------------------- 
          |Ayes:|Calderon, DeVore,         |Ayes:|Leno, Walters, Caballero, |
          |     |Arambula, Eng, Feuer,     |     |Davis, DeSaulnier,        |
          |     |Hayashi, Ma, Plescia      |     |Emmerson, Huffman,        |
          |     |                          |     |Karnette, Krekorian, La   |
          |     |                          |     |Malfa, Lieu, Ma,          |
          |     |                          |     |Nakanishi, Nava, Sharon   |
          |     |                          |     |Runner, Solorio           |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :  Adopts recent federal legislation to permit an exempt  
          organization to make payments to family members of firefighters  
          that died as a result of the October 2006 Esperanza Incident  
          fire (Esperanza fire).  Specifically,  this bill  :  

          1)Provides that payments made by certain tax exempt  
            organizations to any family member of a firefighter who died  
            as a result of the Esperanza fire shall be treated as related  
            to the organization's tax exempt purpose if the payments are  
            made in good faith using a reasonable and objective formula  
            consistently applied.

          2)Applies only to payments made on or after October 26, 2006,  
            and before June 1, 2007. 

          3)Contains legislative findings and declarations that the  
            enactment and retroactive application of the act are necessary  
            for the public purpose of providing relief to the families of  
            the fallen firefighters without interfering with the exempt  
            status of the organization providing the relief.

          4)Provides for a tax levy and is effective immediately.








                                                                  SB 41
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           EXISTING LAW  :  

          1)Exempts certain corporations from tax, provided the  
            corporation is organized in accordance with, and continually  
            complies with, specified rules.  Relevant to this bill are  
            rules that prohibit payments by exempt organizations that  
            inure to the benefit of any private shareholder or individual.  
             Should an organization be formed with an express purpose of  
            benefiting individuals in times of need, the organization must  
            strictly comply with rules governing accounting for and  
            distribution of funds set out in guidelines issued by the  
            Internal Revenue Service.  

          2)States that failure to comply with the rules might place the  
            organization's tax exempt status at risk.  In general, the  
            target group must be large or indefinite enough that providing  
            assistance benefits the community as a whole.

           FISCAL EFFECT  :  According to Franchise Tax Board staff, the  
          revenue loss for fiscal year 2006-07 is expected to be  
          insignificant (less than $150,000).  Any revenue loss occurring  
          with passage of this bill would be directly related to the fact  
          that an organization would retain its tax-exempt status (thereby  
          not becoming taxable) even though the organization made payments  
          to the families of the five fallen firefighters.  It is a  
          one-year impact only because the exempt status would likely be  
          restored the year following the disqualifying distributions.

           COMMENTS  :  Proponents support the action to adopt the federal  
          emergency legislation to allow charitable donations received to  
          be distributed to families of the fallen firefighters.   
          Proponents state, "[t]he people of this state recognize that  
          brave men and women are on the alert to respond within minutes  
          to a wide range of disasters" and assert that this bill  
          formalizes the intent of the people.  According to proponents,  
          this bill will facilitate distribution of the funds received to  
          the survivors of the five brave firefighters.

          Coverage of the Esperanza fire and the resulting loss of life  
          for five firefighters yielded cash contributions from people  
          throughout the country.  A primary recipient of the funds  
          incorrectly accounted for the contributions and was concerned  
          that a subsequent distribution of the funds collected to the  








                                                                  SB 41
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          specific individuals might threaten its tax-exempt status.  This  
          situation is extremely rare; it is not expected to become a  
          problem that the Legislature will be called upon to address in  
          the future except in an extreme circumstance.  In December 2006,  
          similar legislation was enacted at the federal level to address  
          this specific and limited problem.


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


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