BILL ANALYSIS                                                                                                                                                                                                    




                                   REVISED-NEW BILL

             

            SENATE REVENUE & TAXATION COMMITTEE

            Senator Lois Wolk, Chair

                                                  SB 137 - Maldonado

                              As Proposed to be Amended: April 22, 2009

                                                                       

            Hearing: April 22, 2009                         Fiscal: Yes




            SUMMARY:  Requires the State Controller to Pay Interest on  
                      Tax Refunds Delayed By Cash Management Emergency  
                      for Specified Period 


                 

                 EXISTING LAW (Federal and State) prohibits the  
            Internal Revenue Service and the Franchise Tax Board (FTB)  
            from paying interest on personal income tax overpayments  
            before the  later  of the following two dates:

                             45 days after the date the taxpayer files  
                      the return
                             45 days after the date the return is due  
                      (April 15th for the great majority of personal  
                      income taxpayers)

                 EXISTING LAW requires the state to pay interest in the  
            amount of the federal short-term rate plus 3%.

                 EXISTING LAW deems withholding amounts and estimated  
            payments paid on the due date of the return.  State law  
            provides that  returns  of tax filed before the due date  
            shall be considered as filed on that day, but  tax payments   








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            are deemed paid on the last day prescribed by law for  
            filing.  Additionally, the FTB uses above deemed paid dates  
            for interest calculations, credits or refunds for estimated  
            payments, and court-ordered refunds resulting from  
            overpayments.  

                 EXISTING LAW directs the State Controller to account  
            for and control the payment of tax refunds.

                 THIS BILL provides that notwithstanding the interest  
            payment requirements and deemed paid and deemed received  
            dates listed above, the Controller must pay interest on  
            refund warrants for personal income taxpayers when he or  
            she determines that a cash management emergency exists and  
            postpones the issuance of refund warrants under the  
            following conditions.  The Controller must pay interest  
            during the interest period, which begins 15 days after the  
            date the return is filed or 15 days after the date the  
            issuance of the refund warrant is postponed, whichever is  
            later, and lasts until 30 days before the refund warrant is  
            issued.




            FISCAL EFFECT: 

                 Because the author is only amending the measure today,  
            no FTB revenue estimate is available.  Committee Staff  
            estimate minimal costs for tax refunds for the 2008 tax  
            year because the measure would not affect many returns;  
            however, should California experience protracted cash  
            management crises in the future, the costs of the measure  
            would increase significantly as the state would have to pay  
            interest on more tax refunds.  


            


            COMMENTS:









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            A.   Purpose of the Bill

                 According to the Author, "Earlier this year, the State  
            Controller's Office (SCO) delayed tax refunds as a direct  
            response to the state's fiscal crisis.  The SCO, which acts  
            as the state's accountant, said he had no choice but to  
            delay these payments for 30 days because the state was  
            running out of cash. 

                 The SCO withheld approximately $1.9 billion in  
            refunds.  The refunds are overpayments from the taxpayers  
            to the state.  Many residents depended on these refunds for  
            health care, rent and other vital services. By delaying  
            these refund, many innocent taxpayers incurred additional  
            costs. 
                 SB 137 is common sense legislation that will prevent  
            taxpayers from being penalized solely because they paid  
            their taxes early.  This bill charges interest the SCO if  
            tax refund payments are delayed.  This interest will be  
            paid back to the taxpayer whose money is being withheld." 

            B.   May You Live in Interesting Times

                 In fiscal year 2007-08, FTB processes over 17 million  
            tax returns per year, and approximately 11 million include  
            a claim for refund.  The average return is processed in 25  
            days, although taxpayers filing electronically receive  
            refunds much more quickly than those filing a paper return.  
             Current law states that refunds are not technically due  
            until May.  Only rarely did the deadlines in the law  
            require interest payment - of $8.5 billion in refunds, the  
            state paid merely $10 million in interest.

                 However, taxpayers expecting quick refunds this year  
            (ahead of the statutory requirement) did not receive them  
            because of the state's unprecedented cash flow shortage.   
            On February 2nd, State Controller John Chiang announced a  
            thirty day delay in the payment of tax refunds, frustrating  
            more than three million taxpayers who had already filed  
            their 2008 taxes and expected more than $2 billion in  
            refunds.  The Controller decided to toll these refunds,  
            instead making other claims and payments because the state  








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            did not have enough money to pay all claims.  After  
            enactment of the 2009-10 state budget, the Controller began  
            sending out the delayed tax refunds on March 6th, and paid  
            all claims by March 25th.  



            C.   Stay Just A Little Bit Longer?

                 In response to the Controller's decision earlier this  
            year forced by the state's cash crisis, SB 137 provides an  
            exception from the usual interest calculation and tax  
            refund laws that guide taxpayers and FTB.  However, while  
            the bill moves the beginning date of the interest rate  
            period forward when the Controller delays tax refunds due  
            to a cash management crisis, the bill terminates the  
            interest payment period as much as the date 30 days before  
            the Controller refund warrant is issued, consistent with  
            current law guiding interest payment.  FTB determines this  
            date based on how quickly the Controller can issue the  
            refund warrant after the tax return is provided, which is  
            generally five days for individual personal income  
            taxpayers, and will generally limit the interest period to  
            limit General Fund costs.  For example:

                             A taxpayer files his or her return on  
                      February 1st, and the Controller declares that he  
                      or she will delay the tax return because of a  
                      cash crisis on February 7th.  The interest period  
                      (the period in which the state must pay interest  
                      on the overpayment each day) begins 15 days after  
                      the date the return is filed (February 16th).   
                      Later, on March 7th, the Controller starts  
                      issuing tax refunds because cash is available.   
                      FTB may declare the end of the interest period on  
                      February 12th, 25 days before the date the  
                      Controller issues the tax refund, resulting in no  
                      payment of interest.
                             Again, the taxpayer files his or her  
                      return on February 1st, and the Controller  
                      declares that he or she will delay the tax return  
                      because of a cash crisis on February 7th.  The  








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                      taxpayer files his or her return on February  
                      10th, and the interest period begins on February  
                      26th (15 days after the return is filed).   
                      However, this time the cash crisis is worse, and  
                      the Controller must delay the tax refund until  
                      April 1st, which leads the FTB determines the end  
                      of the interest period to be March 7th, allowing  
                      the taxpayer 10 days of interest.

                 The amount of interest, and therefore the fiscal cost,  
            and effect upon the Controller's cost-benefit decision is  
            contingent on the duration of the cash crisis.  SB 137 may  
            not compel any additional interest in a cash crisis that  
            delays tax refunds less than 30 days, and minimal interest  
            for ones that last a few days more, such as this year's  
            crunch.   However, the bill's costs will increase as a cash  
            crisis worsens.



            D.   Of Deck Chairs and the Titanic

                 SB 137 seeks to change the Controller's cost-benefit  
            calculation when determining which claims he or she will  
            pay by requiring the payment of interest on some tax  
            returns: if the state has to pay more interest earlier, the  
            decision to toll tax refunds becomes more expensive,  
            thereby making the Controller less likely to delay these  
            payments in the future.  However, in the case the state  
            cannot pay all its claims, should the Legislature put the  
            Controller in an even more difficult position during an  
            emergency situation by requiring payment of extra interest?  
             Should the Legislature realign the Controller's incentives  
            when California voters elected him or her to use their best  
            judgment when prioritizing who the state pays and who the  
            state stiffs?  Because SB 137's costs grow the longer tax  
            refunds are delayed, the measure would nudge the Controller  
            away from paying contractors, vendors, state employees, and  
            possibly bondholders due to the increased interest required  
            by the measure, and that nudge could turn into a push if  
            the cash crisis persists and SB 137 interest payments  
            accumulate.  While taxpayers should expect timely refunds  








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            of overpaid taxes, under current law interest is precluded  
            until after May 30th.  The Committee may wish to consider  
            the wisdom of adding costs to the state during a fiscal  
            meltdown.  

            

            E.   Gears and Wheels

                 State law must provide specific dates in which taxes  
            are deemed paid, and returns deemed filed to properly  
            calculate the number of days upon which to base interest  
            calculations; without commonly accepted dates, taxpayers  
            and tax enforcement agencies could fight endlessly.  In  
            California, taxes are deemed paid on the date the return is  
            due, but returns are deemed filed on the day the return is  
            filed.  Taxpayers must overpay taxes for the state to issue  
            a refund, but taxes aren't deemed paid until April 15th  
            (the due date of almost all individual personal income tax  
            returns), and interest isn't allowed until May 30th.  To  
            remedy this problem, SB 137 excludes the application of  
            these sections explicitly, thereby removing the statutory  
            conflict provided by the measure's direction to pay  
            interest beginning before April 15th.

            

            F.   Just People
                 The March 31, 2009 version of SB 137 applies to both  
            individuals and fiduciaries, thereby excluding some  
            business taxpayers that file under the Personal Income Tax  
            instead of the Corporation Tax Law, such as "S"  
            corporations and limited liability companies, among others.  
             The current version of the bill applies only to  
            individuals, which state law describes as "natural persons"  
            (as opposed to unnatural ones).  In either case, SB 137  
            allows interest for delayed tax refunds just for people.

            

            G.   Related Legislation









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                 AB 1251 (Saldana) requires FTB to pay interest on PIT  
            refunds delayed as a result of the Controller's decision.  




            Support and Opposition

                 Support:State Controller John Chiang (if amended),  
            previous version



                 Oppose:None Received



            ---------------------------------

            Consultant: Colin Grinnell