BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1087
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          ASSEMBLY THIRD READING
          AB 1087 (Ma)
          As Amended June 1, 2009
          Majority vote   

           REVENUE & TAXATION  6-1         APPROPRIATIONS      12-5        
           
           ------------------------------------------------------------------ 
          |Ayes:|Charles Calderon, Beall,  |Ayes:|De Leon, Ammiano, Charles  |
          |     |Coto, Ma, Portantino,     |     |Calderon, Davis, Fuentes,  |
          |     |Fong                      |     |Hall, John A. Perez,       |
          |     |                          |     |Price, Skinner, Solorio,   |
          |     |                          |     |Torlakson, Krekorian       |
          |     |                          |     |                           |
          |-----+--------------------------+-----+---------------------------|
          |Nays:|DeVore                    |Nays:|Nielsen, Duvall, Harkey,   |
          |     |                          |     |Miller,                    |
          |     |                          |     |Audra Strickland           |
          |     |                          |     |                           |
           ------------------------------------------------------------------ 
           SUMMARY  :  Modifies the current sales and use tax (SUT) exclusion  
          for separately stated transportation charges.  Specifically,  
           this bill  provides that charges for transportation are  
          separately stated for purposes of the exclusion if the charges  
          are stated as a single amount and are not included within a  
          single amount that combines transportation charges with other  
          charges.  

          EXISTING LAW  :

          1)Imposes a sales tax on retailers for the privilege of selling  
            tangible personal property (TPP), absent a specific exemption.  
             The tax is based upon the gross receipts from sales of TPP in  
            this state.  

          2)Imposes a use tax on the storage, use, or other consumption in  
            this state of TPP purchased from any retailer for storage,  
            use, or other consumption in this state, absent a specific  
            exemption.

          3)Provides, under the SUT Law, that the terms "gross receipts"  
            and "sales price" do  not  include separately stated charges for  
            transportation from the retailer's place of business or other  
            point from which shipment is made directly to the purchaser.   








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            However, the exclusion may not exceed a reasonable charge for  
            transportation "by facilities of the retailer or the cost to  
            the retailer of transportation by other than facilities of the  
            retailer."  In other words, in cases where the retailer uses a  
            common carrier, the exclusion is limited to the retailer's  
            cost for the transportation.  

           FISCAL EFFECT  :  According to the Assembly Appropriations  
          Committee, the Board of Equalization (BOE) estimates this bill  
          would result in an annual increase in sales tax revenues of $3.8  
          million, of which $2.5 million would accrue to the General Fund  
          and the remainder would accrue to special funds and local funds.  


           COMMENTS  :  The author states, "AB 1087 will provide much needed  
          simplicity and clarity for retailers in California and the Board  
          of Equalization in determining the extent to which delivery  
          charges are subject to sales tax.  With the changes proposed in  
          this bill, the applicable sales tax can be collected from the  
          ultimate consumers at the time of the transaction just as other  
          sales taxes are paid.  These changes will streamline the  
          accounting process for small businesses and other retailers that  
          offer delivery services to their customers.  They will also  
          greatly ease administrative and audit burdens for retailers and  
          the Board of Equalization."  

          This bill is sponsored by the California Retailers Association,  
          which states:

               Most retailers charge their customers a flat fee for  
               delivery of merchandise.  (The amount of the fee may  
               be based on the total purchase price for the  
               merchandise.)  In many instances, the amount the  
               delivery company charges the retailer exceeds what the  
               retailer charged its customer, resulting in no tax  
               being due.  However, to the extent the delivery  
               company charges the retailer less than the amount the  
               retailer charged the customer for the delivery, this  
               difference is not excluded from the definition of  
               'sales price' or 'gross receipts' and is thus subject  
               to sales tax.  At the time the customer is completing  
               the transaction, the retailer typically has no way of  
               knowing the exact amount that the delivery company  
               will charge for the delivery, thus the retailer cannot  








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               effectively collect the proper amount of sales tax  
               from the customer.  This puts retailers in the  
               untenable position of being forced to pay sales tax  
               out of their pockets that should be paid by the  
               ultimate consumers.

          Committee Staff Notes:

          1)Revenue and Taxation Code (R&TC) Section 6011 and 6012 impose  
            SUT on all charges related to the retail sale of TPP, except  
            those charges specifically excluded.  For example, current law  
            excludes from the definition of "sales price" and "gross  
            receipts" (i.e., the tax measure) certain separately stated  
            transportation charges.  [R&TC Sections 6011(c)(7) and  
            6012(c)(7)].  This exclusion, however, may not exceed "a  
            reasonable charge for transportation by facilities of the  
            retailer or the cost to the retailer of transportation by  
            other than facilities of the retailer."  

          2)Existing law also provides that the terms "sales price" and  
            "gross receipts" include the cost of services that are part of  
            the sale of TPP.  In other words, related handling charges are  
            currently taxable whether separately stated or not.  Moreover,  
            under existing law, a charge for "shipping and handling" does  
            not constitute a separate statement of shipping charges, and,  
            if there is no further itemization, the entire charge would be  
            included in the computation of tax. 

          3)To further complicate matters, BOE notes, "Although a  
            designation such as, 'shipping and handling' or 'postage and  
            handling' is not regarded as a separate statement of  
            transportation charges, under the Board's Regulation 1628,  
            Transportation Charges, the designation 'postage and  
            handling,' 'shipping and handling,' or similar designation,  
            coupled with a statement of the actual amount of postage  
            placed on the package mailed to a customer, constitutes a  
            separate statement of transportation charges and those  
            transportation charges are excludable from the measure of  
            tax."
           

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









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