BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                  AB 2676|
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                                 THIRD READING


          Bill No:  AB 2676
          Author:   Ma (D)
          Amended:  4/27/10 in Assembly
          Vote:     21

           
           SENATE REVENUE & TAXATION COMMITTEE  :  3-0, 6/23/10
          AYES:  Wolk, Alquist, Padilla
          NO VOTE RECORDED:  Walters, Ashburn
           
          SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8
           
          ASSEMBLY FLOOR  :  49-28, 6/1/10 - See last page for vote


           SUBJECT  :    Board of Equalization:  administration

           SOURCE  :     Board of Equalization


           DIGEST  :    This bill makes permanent the use-tax reporting  
          line currently found on state personal income tax returns  
          and makes several other changes relating to tax laws  
          administered by the Board of Equalization. 

           ANALYSIS  :    

          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  
             retailer's gross receipts from TPP sales in this state. 
                                                           CONTINUED





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          2. Imposes a complementary use tax on the storage, use, or  
             other consumption of TPP purchased out of state and  
             brought into California. The use tax is imposed on the  
             purchaser, and unless the purchaser pays the use tax to  
             an out-of-state retailer registered to collect  
             California's use tax, the purchaser remains liable for  
             the tax.  The use tax is set at the same rate as the  
             state's sales tax and must be remitted to the Board of  
             Equalization (BOE). 

          3. Allows taxpayers to elect to report and remit qualified  
             use tax on an acceptable income tax return, as defined. 

          4. Provides that, upon the termination, dissolution, or  
             abandonment of the business of a corporation,  
             partnership, limited partnership, limited liability  
             partnership, or limited liability company (LLC),  
             specified individuals shall be held personally liable  
             for any unpaid SUT if the individual willfully fails to  
             pay any sales and use tax (SUT) owed by the business  
             entity, as specified. 

          5. Provides the Franchise Tax Board, but not BOE, with  
             access to information contained in the new employee  
             registry maintained by the Employment Development  
             Department (EDD). 

          This bill:

          1. Reinstates and makes permanent the statutory provisions  
             allowing taxpayers to elect to report and remit  
             qualified use tax on an acceptable income tax return, as  
             defined. 

          2. Provides that, upon suspension of a "closely held  
             corporation" or "closely held LLC", certain individuals  
             shall be held personally liable for any unpaid SUT  
             liability of that business entity incurred during the  
             period of suspension. 

             A.    Provides that the following individuals shall be  
                subject to personal liability: 








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                (1)      Any corporate officer, shareholder, or  
                   member with "control over operations or  
                   management" during a time in which the entity's  
                   powers, rights, and privileges are suspended. 

                (2)      Any "responsible person" who fails to pay  
                   any taxes due from the business entity during a  
                   time in which the entity's powers, rights, and  
                   privileges are suspended. 

             B.    Provides that the corporate officer, shareholder,  
                member, or responsible person shall be liable for the  
                unpaid tax, along with interest and penalties,  
                regardless of the basis for the business entity's  
                suspension. 

             C.    Provides that, if the business entity can  
                establish that it has taken all actions necessary to  
                qualify for revival within 60 days of suspension, no  
                personal liability shall be imposed. 

             D.    Provides that personal liability applies only when  
                BOE establishes that, during the period of  
                suspension, the business entity did any of the  
                following: 

                (1)      Sold TPP in the conduct of its business and  
                   collected sales tax reimbursement without  
                   remitting the tax when due.

                (2)      Collected use tax without reporting and  
                   paying the tax. 

                (3)      Consumed TPP without paying the applicable  
                   tax to the seller or BOE. 

             E.    Defines a "closely held corporation" as a  
                corporation in which ownership is concentrated in one  
                individual, one family, or a small number of  
                individuals and the majority stockholders manage the  
                business or have delegated the management to the  
                corporate officers. 

             F.    Defines a "closely held LLC" as an LLC in which  







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                ownership is concentrated in one individual, one  
                family, or a small number of individuals, and the  
                majority members manage the business or have  
                delegated management to the company officers. 

             G.    Defines "control over operations or management" to  
                mean the power to manage or affect day-to-day  
                operations of the business.  It shall be rebuttably  
                presumed that an officer has control over operations  
                and management. 

             H.    Defines a "responsible person" as any officer,  
                shareholder, or member who is charged with the  
                responsibility for the filing of returns or the  
                payment of tax or who has a duty to act for the  
                business entity in complying with any provision of  
                the SUT law, and who derives a direct financial  
                benefit from the failure to pay the tax liability. 

             I.    Provides that a suspended corporation or LLC shall  
                remain liable for the unpaid tax, interest, and  
                penalties incurred during the period of suspension  
                without regard to any personal liability imposed. 

          3. Adds personal liability provisions comparable to those  
             contained in Section 6829 of the Revenue and Taxation  
             Code, as amended, to various special tax and fee  
             programs that BOE administers.  Specifically, personal  
             liability provisions would be added to the following: 

                   The Motor Vehicle Fuel Tax Law
                   The Use Fuel Tax Law
                   The Hazardous Substances Tax Law
                   The Integrated Waste Management Fee Law
                   The Oil Spill Response, Prevention, and  
                Administration Fees Law
                   The Fee Collection Procedures Law
                   The Diesel Fuel Tax Law

          4. Grants BOE authority to use the information contained in  
             the EDD new employee registry for tax or fee enforcement  
             purposes. 

           Comments  







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          The author states:  "AB 2676 is sponsored by the Board of  
          Equalization and contains various provisions that will  
          assist the BOE in its administration of its various tax and  
          fee programs." 

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes    
          Local:  No

           SUPPORT  :   (Verified  8/2/10)

          Board of Equalization (source)


           ASSEMBLY FLOOR  : 
          AYES:  Ammiano, Arambula, Bass, Beall, Blakeslee, Block,  
            Blumenfield, Bradford, Brownley, Buchanan, Caballero,  
            Charles Calderon, Carter, Chesbro, Coto, Davis, De La  
            Torre, De Leon, Eng, Evans, Feuer, Fong, Fuentes,  
            Furutani, Galgiani, Hall, Hayashi, Hernandez, Hill,  
            Huffman, Jones, Lieu, Bonnie Lowenthal, Ma, Mendoza,  
            Monning, Nava, Portantino, Ruskin, Salas, Saldana,  
            Skinner, Solorio, Swanson, Torlakson, Torres, Torrico,  
            Yamada, John A. Perez
          NOES:  Adams, Anderson, Bill Berryhill, Conway, Cook,  
            DeVore, Emmerson, Fletcher, Fuller, Gaines, Garrick,  
            Gilmore, Hagman, Harkey, Huber, Jeffries, Knight, Logue,  
            Miller, Nestande, Niello, Nielsen, Norby, V. Manuel  
            Perez, Silva, Smyth, Tran, Villines
          NO VOTE RECORDED:  Tom Berryhill, Audra Strickland, Vacancy


          DLW:mw  8/3/10   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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