BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 2671
                                                                  Page  1

          Date of Hearing:  April 12, 2010

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                            Anthony J. Portantino, Chair

                  AB 2671 (Cook) - As Introduced:  February 19, 2010

          Majority vote.  Tax levy.  Fiscal committee.

           SUBJECT  :  Corporation tax:  minimum franchise tax:  member of  
          the United States Armed Forces.

           SUMMARY  :  Exempts from the annual minimum franchise tax any  
          corporation that is solely owned by a deployed member of the  
          United States (U.S.) Armed Force.  Specifically,  this bill  :  

          1)Provides that a corporation solely owned by a deployed member  
            of the U.S. Armed Forces is not subject to the minimum  
            franchise tax for any taxable year in which the owner is  
            deployed, provided that the corporation operates at a loss or  
            ceases operation.

          2)Defines "deployed" as being called to active duty or active  
            service during a period when a Presidential Executive order  
            specifies that the U.S. is engaged in combat or homeland  
            defense.  The definition of "deployed" does not include a  
            temporary duty for the sole purpose of training or processing  
            or a permanent change of station.  

          3)Defines the phrase "operating at a loss" as negative net  
            income as defined in Revenue and Taxation Code (R&TC) Section  
            24341. 

          4)Corrects an erroneous cross-reference and deletes provisions  
            relating to financial asset securitization investment trusts.   


          5)Takes effect immediately as a tax levy and applies to taxable  
            year beginning on or after January 1, 2010.  

           EXISTING LAW  imposes franchise tax on all corporations doing  
          business in California equal to 8.84% of the taxable income  
          attributable to California.  A minimum franchise tax of $800 is   
                  imposed on all corporations that are incorporated under  
          the laws of California, qualified to transact intrastate  








                                                                  AB 2671
                                                                  Page  2

          business in California, or are doing business in California.   
          Taxpayers must pay the minimum franchise tax only if it is more  
          than their regular franchise tax liability.  Specifically:

          1)Limited exceptions exist with respect to imposition of the  
            minimum franchise tax.  For instance, credit unions and  
            nonprofit organizations are not subject to the minimum  
            franchise tax and a corporation is not subject to the minimum  
            franchise tax for its first taxable year.  However, even  
            though a corporation is not subject to the minimum tax in its  
            first taxable year, it will be subject to franchise tax in its  
            first taxable year based on its taxable income.

          2)According to the Franchise Tax Board (FTB), for taxable years  
            beginning on or after January 1, 1997, only taxpayers with net  
            income less than approximately $9,040 pay the minimum  
            franchise tax because the amount of measured tax owed would be  
            less than $800 ($9,039 x 8.84% = $799). 

          3)Limited partnerships (LPs), limited liability partnerships  
            (LLPs), and limited liability corporations (LLCs) that are  
            doing business in California, registered or qualified to do  
            business in California, or formed in this state are subject to  
            annual tax in an amount equal to the minimum franchise tax,  
            currently set at $800.  These entities (known as 'pass-through  
            entities') are not subject to any tax based on taxable income.  
             Rather, the items of income, gain, loss, deduction and credit  
            are passed-through to the owners and reported on their  
            respective income or franchise tax returns. 

          4)Real estate mortgage investment conduits (REMICs) are subject  
            to and required to pay the minimum franchise tax.  Regulated  
            investment companies (RICs) and real estate investment trusts  
            (REITs) organized as corporations are also subject to and  
            required to pay the minimum franchise tax.  RICs, REITs, and  
            REMICs, are entities authorized by the federal government for  
            special tax treatment.  California conforms in large part to  
            federal tax provisions but subjects each entity to payment of  
            the annual minimum tax.

           FISCAL EFFECT  :  The FTB staff estimates this bill will result in  
          a negligible revenue loss of less than $100,000 each fiscal year  
          (FY), beginning with FY 2010-11. 

           COMMENTS  :   








                                                                  AB 2671
                                                                  Page  3


           1)The purpose of this bill  .  According to the author, this bill  
            is intended to provide tax relief to members of the U.S. Armed  
            Forces called to service to defend the nation.  

           2)The Minimum Tax in Other States  .  According to FTB, the  
            following states currently impose a minimum franchise tax:

             a)   Illinois has a minimum 1% tax based on "paid-in" capital  
               (calculated using the shares of stock issued by the  
               corporation as disclosed in the annual statement reported  
               to the Illinois Secretary of State).  The tax ranges from a  
               minimum of $25 to a maximum of $1 million. 

             b)   Massachusetts imposes the greater of a corporate excise  
               tax of 9.5% based on taxable income or a minimum tax equal  
               to $456.

             c)   Beginning January 1, 2008, Michigan taxpayers are  
               subject to the Michigan Business Tax.  The Michigan  
               Business Tax is composed of two taxes - a business income  
               tax of 4.9% on every taxpayer with business activity in the  
               state, and a modified gross receipts tax of 0.80% on every  
               taxpayer having nexus with Michigan.  

             d)   Minnesota imposes a franchise tax on a corporation's  
               taxable income at the rate of 9.8%.  In addition, a minimum  
               franchise tax, ranging from $0 to $5,000, is imposed based  
               on the sum of the property determined by property, payroll,  
               and sales in the state.  

             e)   New York imposes a franchise tax of 7.1% based on net  
               income plus a fixed dollar minimum tax based on gross  
               payroll.  The fixed dollar minimum tax ranges from $100 to  
               $1,500.

           3)FTB's Implementation Concerns .  The FTB staff notes that,  
            under this bill, a member of the U.S. Armed Forces may be  
            deployed to a location where there is no combat during a  
            period when a Presidential Executive order specifies that the  
            U.S. is engaged in combat or homeland defense.  If the  
            author's intent is to limit the tax relief only to a member of  
            the Armed Forces deployed to a combat zone, this bill needs to  
            be amended.  









                                                                  AB 2671
                                                                  Page  4

           4)Committee staff notes all of the following  :

             a)   The minimum franchise tax was enacted to ensure that all  
               corporations pay at least a minimum amount of franchise tax  
               for the privilege of doing business in this state,  
               regardless of the corporation's income or loss.  Thus, the  
               minimum franchise tax is not technically an "income tax",  
               but rather it is a tax on the right to exercise the powers  
               granted to a corporation doing business in California.   
               Even when a corporation earns no income, it still receives  
               the benefits of its corporate status, including the limited  
               liability protection under the laws of this state. 

             b)   California's minimum tax was increased from $100 to $200  
               in 1972.  It was increased to $300 in 1987, to $600 in  
               1989, and to $800 in 1990.  It has never been shown that  
               the minimum franchise tax discourages businesses,  
               particularly, since small businesses can always organize as  
               sole proprietorships to avoid paying the minimum franchise  
               tax. 

             c)   While cognizant of the personal sacrifices made by  
               members of the military, the Committee staff would like to  
               highlight the fact that this bill would favor one group of   
                      taxpayers over another and would create a precedent  
               for a special tax treatment for other residents of  
               California whose service the state wishes to recognize  
               (e.g., police, firemen, teachers) or those who need extra  
               financial support (e.g. disabled, elderly).  

             d)   The provisions of this bill apply only to corporations  
               but most small businesses operate as "pass-through"  
               entities, and not as "C" corporations.  Committee staff  
               recommends that this bill be amended to include LLCs,  
               partnerships, qualified Subchapter "S" corporations, and  
               other eligible "pass-through" business entities in order to  
               provide for a uniform treatment of all small businesses. 

             e)   It is unclear what the phrase "ceases operation" means;  
               the lack of the definition may crease confusion and  
               potentially lead to litigation between the taxpayer and the  
               FTB. Committee staff suggests that the author amend this  
               bill to define that phrase.  

           5)Sunset Date  .  This bill lacks a sunset date to allow periodic  








                                                                  AB 2671
                                                                  Page  5

            legislative review of this tax expenditure.  The Committee  
            staff recommends an amendment to add a sunset date. 

           6)Related legislation  .

          AB 2126 (Garrick), introduced in the 2009-10 Legislative  
            Session, exempts a new corporation from the annual minimum  
            franchise tax and reduces the amount of that tax from $800 to  
            $100 for nine years thereafter.  AB 2126 is set for a hearing  
            in this Committee on April 12, 2010. 

          AB 327 (Garrick), introduced in the 2009-10 Legislative Session,  
            would have reduced the minimum franchise tax for corporation  
            as well as pass-through entities from $800 to $100.  AB 327  
            was held under submission in this Committee.

          AB 2178 (Garrick), introduced in the 2007-08 Legislative  
            Session, would have reduced the minimum franchise tax from  
            $800 to $200.  AB 2178 was held under submission in this  
            Committee. 

          AB 1179 (Garrick), introduced in the 2007-08 Legislative  
            Session, is similar to this bill.  AB 1179 was held in this  
            committee.   

          AB 1419 (Campbell), introduced in the 1997-98 Legislative  
            Session, would have reduced the minimum franchise tax for a  
            qualified corporation from $800 to $100.  AB 1419 failed  
            passage in the Senate Revenue and Taxation Committee.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          None on file

           Opposition 
           
          None on file
           
          Analysis Prepared by  :  Oksana Jaffe / REV. & TAX. / (916)  
          319-2098