BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1486
                                                                  Page  1

          CONCURRENCE IN SENATE AMENDMENTS
          AB 1486 (Furutani)
          As Amended  July 14, 2009
          Majority vote.  Tax levy.
           
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          |ASSEMBLY:  |76-0 |(June 2, 2009)  |SENATE: |38-0 |(August 27,    |
          |           |     |                |        |     |2009)          |
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           Original Committee Reference:    REV. & TAX.  

           SUMMARY  :  Provides that specified tax-exempt organizations shall  
          be deemed consumers, rather than retailers, with respect to  
          certain transfers of tangible personal property (TPP) to their  
          members.  

           The Senate amendments  modify one of the requirements for  
          preferential consumer status, by providing that the TPP may not  
          be distributed for purposes of organized political campaigning  
          or issue advocacy.  

          EXISTING LAW  :

          1)Imposes a sales tax on retailers for the privilege of selling  
            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 Internal Revenue Code (IRC) Section  
               501(c), for the federal exemption of specified  
               organizations, including corporations, community chests, or  
               trusts, organized exclusively for religious, charitable,  
               scientific, literary, educational, or other specified  
               purposes.  
          AS PASSED BY THE ASSEMBLY  , this bill:

             1)   Provided that an organization described in IRC Section  
               501(c) "is a consumer of, and shall not be considered a  
               retailer within the provisions of [the Sales and Use Tax  
               Law] for purposes of any transfer of" TPP to its members,  








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               if the following requirements were met:

             a)   The TPP bears a logo or other identifying mark of the  
               organization and is a promotional item or other item  
               commonly associated with use by a member to demonstrate the  
               member's association with the organization;


             b)   The member's cost is not more than the tax-exempt  
               organization's cost to obtain and transfer the TPP,  
               including any applicable sales or use tax (SUT) paid by the  
               organization; 


             c)   The organization takes reasonable steps to ensure that  
               no member is allowed to acquire more than 30 identical  
               items of TPP or to resell the items to another person; and,


             d)   The TPP is not used for political campaigning or issue  
               advocacy.


             2)   Defined the term "members" by reference to Corporations  
               Code Section 5056.


             3)   Provided that, notwithstanding existing law, the state  
               shall not reimburse any local agency for any SUT revenues  
               lost as a result of this bill.


             4)   Sunsets on January 1, 2015.

           FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, pursuant to Senate Rule 28.8, negligible state costs.  
           

           COMMENTS  :  The author states, "Assembly Bill 1486 attempts to  
          correct a problem non-profit entities face when they purchase  
          items to sell, in turn, to their members.  Under current law, if  
          an organization registered as a 501(c) of the Internal Revenue  
          Code purchases items to sell to its members and pays the  
          appropriate sales tax on those items at the time of initial  
          purchase, the organization is required to also collect sales tax  








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          on the items when it makes a sale to its members. 

          "Non-profit entities are not properly equipped to collect sales  
          tax on items that they sell to their members.  Furthermore,  
          appropriate sales taxes have already been paid for the items at  
          the initial point of purchase, thus there is not a need to  
          collect additional sales tax on items that are being sold to an  
          organization's membership at or below cost."

          Proponents state, "This change will allow a nonprofit/501(c), if  
          in the event they have already paid taxes on items purchased, to  
          sell them to their members without having to act as a tax  
          collector."


          BOE notes the following in its staff analysis of this bill:


             1)   "Under the law, every retailer or any other person that  
               makes three or more retail sales of [TPP] of a kind the  
               retail sale of which is taxable in this state is required  
               to obtain a seller's permit and report the tax on his or  
               her sales on a return prescribed by the Board.  However,  
               California's Sales and Use Tax Law places a variety of  
               retailers making taxable sales of [TPP] under a 'consumer'  
               reporting status.  Under a 'consumer' reporting status, a  
               qualifying retailer making otherwise taxable sales is not  
               required to obtain a seller's permit or report tax on those  
               sales.  Rather, the qualifying retailer is only required to  
               pay tax on his or her cost of the taxable components of the  
               products he or she sells."

             2)   This bill only applies to promotional items sold at  
               cost.  "As long as a nonprofit organization only makes  
               sales of [TPP] described in the bill, then the nonprofit  
               organization would not need to possess a seller's permit,  
               file sales tax returns, or remit sales tax on those sales.   
               However, if a nonprofit organization makes any other sales  
               of [TPP], or sells the promotional items even slightly  
               above cost, they would still be required to file sales tax  
               returns and maintain records to report the proper amount of  
               tax."











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          Committee staff notes:


             1)   What is "consumer" status?:  "Consumer" reporting status  
               is conferred on specified entities to alleviate the burden  
               of registering with BOE as a retailer of TPP.  At the same  
               time, consumer status minimizes the revenue losses often  
               associated with outright exemptions from tax.  Consumer  
               status has been conferred on a wide range of entities,  
               including optometrists, veterinarians, licensed hearing aid  
               dispensers, and others with respect to certain TPP sales.  

             2)   Applies to all organizations described in IRC Section  
               501(c):  As noted above, this bill provides that an  
               organization described in IRC Section 501(c) is a consumer,  
               and shall not be considered a retailer, with respect to  
               specified transfers of TPP.  IRC Section 501(c)(3), with  
               which most people are familiar, provides tax exempt status  
               to corporations, community chests, funds, or foundations  
               organized and operated exclusively for religious,  
               charitable, scientific, or other specified purposes.  It  
               should be noted, however, that this bill would confer  
               consumer status to organizations exempt under other  
               provisions of IRC Section 501(c) (e.g., labor,  
               agricultural, or horticultural organizations, business  
               leagues, chambers of commerce, etc.).  


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




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