BILL ANALYSIS                                                                                                                                                                                                    



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          (  Without Reference to File  )

          CONCURRENCE IN SENATE AMENDMENTS
          AB 2 X1 (Evans)
          As Amended December 18, 2008
          Majority vote
           
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          |ASSEMBLY:  |     |(December 8,    |SENATE: |     |(December 18,  |
          |           |     |2008)           |        |     |2008)          |
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               (vote not relevant)                (vote not available)

           SUMMARY  :  This bill eliminates certain taxes currently devoted  
          to transportation and replaces them with an equivalent amount of  
          revenues available to support General Fund (GF) programs.   
          Specifically, this bill: 

          1)Eliminates the existing excise tax on motor vehicle fuel and  
            diesel. Currently, California imposes an excise tax of 18  
            cents per gallon on both motor vehicle fuel and diesel fuel.   
            Proceeds from these taxes are deposited into special  
            transportation funds to support the planning, construction,  
            maintenance, and operation of public streets and highways.  
            This bill repeals these excise taxes effective April 1, 2009.
         
          2)Eliminates existing state sales tax on motor vehicle fuel.   
            California also imposes a sales tax on purchases of motor  
            vehicle and diesel fuels. This bill exempts motor vehicle fuel  
            from the state GF portion of the sales tax, effective April 1,  
            2009.  Sales of motor vehicle fuel, however, would continue to  
            be subject to  special fund  and  local  sales and use taxes.
           
           3)Increases the sales and use tax rate. This bill would raise  
            the GF sales and use tax rate by 0.5%, from 5% to 5.5%,  
            effective February 1, 2009.  
           
           4)Imposes a new oil severance tax.  This bill imposes a  
            severance tax of 9.9% on the extraction of oil from the earth  
            or water within California's jurisdiction, effective July 1,  
            2009. 

          5)Imposes a surtax on the final personal income tax liability.  
            For the 2009 taxable year and each taxable year thereafter,  
            this bill imposes a personal income tax surtax that applies to  








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            all taxpayers and is calculated based on the taxpayer's final  
            tax liability, after application of tax credits.  For the 2009  
            tax year, the surcharge will be imposed at the rate of 2.5%  
            but may be adjusted by the Department of Finance in later  
            years as authorized by this measure.

          6)Establishes a balancing mechanism to ensure that this measure  
            is revenue neutral. This bill authorizes the Director of  
            Finance to reset the personal income tax surcharge rate to  
            ensure the measure is revenue neutral.  Based on actual data  
            received from the Board of Equalization, the Franchise Tax  
            Board, and the Department of Conservation for the prior  
            calendar year, as well as revised projections of revenue in  
            the future year, the director is required to make an annual  
            determination as to whether or not an adjustment in the  
            surcharge rate is necessary.  In the event that the surcharge  
            rate is not sufficient to bring the bill into balance, the  
            Director of Finance is authorized to adjust the oil severance  
            tax rate. 

          7)Specifies the time period for bringing a legal action to  
            challenge any provision of this measure. The bill limits the  
            time period within which a legal action challenging its  
            provisions may be filed to 90 days following the operative  
            date of this bill. 

          8)Provides that the entire measure shall be invalid if any of  
            the revenue raising provisions is invalidated by the courts.

           AS PASSED BY THE ASSEMBLY  , this bill was a vehicle to enact  
          statutory changes relating to the 2008 Budget Act.

           FISCAL EFFECT  :  As shown in the accompanying table, the bill  
          results in special fund decreases and corresponding GF increases  
          of slightly over $1.1 billion in fiscal year (FY) 2008-09, $4.6  
          billion in FY 2009-10, and about $4.7 billion in FY 2010-11.

          
           ----------------------------------------------- 
          |           |2008-09    |2009-10    |2010-11    |
          |-----------+-----------+-----------+-----------|
          |Special    |           |           |           |
          |Fund       |           |           |           |
          |Reductions:|           |           |           |
          |           |           |           |           |








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          |-----------+-----------+-----------+-----------|
          |Excise tax |      -$829|    -$3,209|    -$3,274|
          |on motor   |           |           |           |
          |vehicle    |           |           |           |
          |fuels      |           |           |           |
          |-----------+-----------+-----------+-----------|
          |Sales tax  |       -356|     -1,425|     -1,485|
          |on         |           |           |           |
          |gasoline   |           |           |           |
          |-----------+-----------+-----------+-----------|
          |Total-speci|    -$1,185|    -$4,634|    -$4,759|
          |al funds   |           |           |           |
          |reductions |           |           |           |
          |-----------+-----------+-----------+-----------|
          |General    |           |           |           |
          |Fund       |           |           |           |
          |increases: |           |           |           |
          |-----------+-----------+-----------+-----------|
          |One-half   |        955|      2,260|      2,416|
          |cent sales |           |           |           |
          |tax        |           |           |           |
          |increase   |           |           |           |
          |-----------+-----------+-----------+-----------|
          |2.5%  PIT  |       $150|     $1,500|     $1,400|
          |surcharge  |           |           |           |
          |-----------+-----------+-----------+-----------|
          |9.9% oil   |          0|       $855|       $862|
          |severance  |           |           |           |
          |tax        |           |           |           |
          |-----------+-----------+-----------+-----------|
          |Total-GF   |     $1,105|     $4,615|     $4,678|
          |increases  |           |           |           |
          |-----------+-----------+-----------+-----------|
          |Net Impact |       -$80|       -$19|-$81       |
          |           |           |           |           |
           ----------------------------------------------- 
          
           COMMENTS  :

          1)Existing law imposes a sales or use tax on the sale or use in  
            this state of tangible personal property, absent a specific  
            exemption.  The combined sales tax rate in California  
            currently ranges from 7.25% (for counties with no optional  
            transactions and use taxes) up to 9.25% (for the City of South  
            Gate in Los Angeles County). The combined rate consists of a  








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            state GF rate of 5%, statewide special fund rates totaling  
            1.25%, a local tax rate of 1%, and local optional rates.

            Sales and use taxes, as general taxes on consumption, are  
            generally paid by the consumer. They are considered to be more  
            regressive than some other taxes, such as California's  
            personal income tax, since they absorb a larger portion of the  
            income of lower-income taxpayers than of higher-income  
            taxpayers.  Also, some researchers have asserted that  
            significant increases in sales taxes can have negative impacts  
            on spending and the economy. However, given the imperative of  
            a balanced budget and the magnitude of the current budget  
            shortfall, the economic effects of a sales tax rate increase  
            must be weighed against the economic effects of other options  
            for balancing the budget.

          2)The state's sales and use tax has applied to sales of motor  
            vehicle fuel and diesel fuel since 1972.  Revenues from the  
            sales and use tax on motor vehicle fuel generally flow to  
            special funds to support transportation programs, either under  
            the terms of a "spillover" formula created when the tax was  
            first broadened to include motor vehicle fuel, or through the  
            provisions of Proposition 42 (2002).

          3)Existing law imposes an excise tax of $0.18 per gallon on the  
            removal of motor vehicle fuel or diesel fuel at the refinery  
            or terminal rack, upon entry into the state, and upon sales to  
            an unlicensed person.  The motor vehicle fuel excise tax was  
            first imposed on October 1, 1923 at a rate of 2 cents per  
            gallon.  The tax was increased five times over the next 60  
            years, and was set at 9 cents per gallon on January 1, 1983.   
            In the early 1990s, the tax was increased in increments over  
            several years, until it was set at the current level of 18  
            cents per gallon on January 1, 1994. Under the California  
            Constitution, the proceeds of this tax are used exclusively  
            for state and local transportation purposes.

          4)Existing law imposes a personal income tax (PIT) and provides  
            for six different graduated PIT rates ranging from 1% to 9.3%,  
            with an additional 1% Mental Health Tax on taxable  income  
            over $1 million (Proposition 63, 2004).   Under this measure,  
            the taxpayer's California income tax will be increased only  
            marginally, because the 2.5% surcharge is imposed on the  
            taxpayer's final tax liability, not his or her gross or  
            taxable income.  For example, a taxpayer with tax due of  








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            $1,000 would pay $25 in additional tax, unless the taxpayer is  
            eligible for a dependent care tax credit, which would reduce  
            the additional tax by five dollars. Generally, a married  
            couple filing jointly with adjusted gross income of $75,000  
            would pay approximately $35 as a result of this additional  
            surcharge, whereas joint filers with adjusted gross income of  
            $500,000 would pay around $900.  This additional California  
            income tax surcharge, however, may be deducted by taxpayers on  
            their federal tax returns.  Thus, joint filers who itemize  
            their deductions may be able to deduct between 33% and 35% of  
            that additional surcharge on their federal income tax return.   


          The surcharge rate of 2.5% may be adjusted annually by the  
            Department of Finance based on the department's determination  
            regarding the revenue effect of this bill in any particular  
            fiscal year to ensure that revenue gains from the new and  
            increased taxes enacted by this measure do not exceed the  
            revenue foregone as the result of the partial sales tax  
            exemption for motor vehicle fuel and the repeal of the excise  
            tax on motor vehicle and diesel fuels. The bill additionally  
            provides that FTB shall not adjust withholding tables until  
            2010 to reflect increased tax liability added by this section,  
            and also provides that FTB may not apply penalties on  
            taxpayers who underpay estimated payments in 2009 if the  
            understatement was due to the increased liability resulting  
            from this bill.
           
           5)Currently, California is the only major oil-producing state  
            that does not impose a tax on the extraction of oil from the  
            earth or water.  Existing law, however, does require oil  
            producers to pay to the Department of Conservation a  
            regulatory fee of $0.07023 per barrel of oil produced to fund  
            the department's regulatory programs.  In addition, the law  
            imposes a fee of $0.05 per barrel of oil on persons owning  
            crude oil when it is received at a marine terminal from within  
            the state.  Existing law also imposes sales tax on the sale of  
            motor vehicle fuel and diesel fuel and an excise tax of $0.18  
            per gallon on the removal of motor vehicle fuel or diesel fuel  
            at the refinery or terminal rack, upon entry into the state,  
            and upon sale to an unlicensed person.  Finally, existing law  
            authorizes a 1% ad valorem property tax, to be imposed by  
            counties, on the full cash value of property where the value  
            of the property includes underlying gas and mineral rights  
            and, with respect to oil in the ground, "proved reserves".  








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          The price of California crude oil is normally 15% less than the  
            often-quoted benchmark prices for light crude oil because  
            California crude oil is heavier and more expensive to refine.   
            Revenues from the severance tax will depend on future levels  
            of oil production and the price of oil extracted in  
            California.  Stripper wells - defined as those producing less  
            than 10 barrels of oil per day - would be exempt from the tax  
            if the price of oil they received as of January 1 of the  
            previous year was below $30 per barrel.  This bill also  
            exempts production of oil owned or produced on or behalf of  
            any political subdivision of this state. 

          Taxes of this nature are often passed on to the end consumer.   
            Nevertheless, the Legislative Analyst's Office noted in its  
            2006 report on Proposition 87, which would have imposed a  
            similar oil severance tax, that market forces could ensure  
            that an oil severance tax would not be passed on to consumers.  
             Because California oil refiners have many options for  
            purchasing crude oil in the global oil market, California oil  
            producers will have to maintain competitive prices to retain  
            their share of the market.

          Local property taxes paid on oil reserves could decline modestly  
            under this measure, to the extent that the imposition of the  
            severance tax reduces the value of oil reserves in the ground.  
              

          The severance tax provisions are similar to AB 9 x3 (Nunez),  
            which was introduced in the 2007-08 legislative session.  AB 9  
            x3 would have imposed a 6% severance tax on specified oil  
            producers.  In addition, AB 9 x3 would have levied a 2% surtax  
            on that portion of taxable income or net income, respectively,  
            in excess of $10 million, of taxpayers engaged in the  
            petroleum industry.  

          6)The loss of transportation funding resulting from this bill is  
            offset by new revenues created by other legislation pending in  
            this extraordinary session.  


           Analysis Prepared by  :    Oksana Jaffe / REV. & TAX. / (916)  
          319-2098
                             Brad Williams / APPR. / (916) 319-2081
                             Dan Rabovsky / BUDGET / (916) 319-2099 








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