BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 318
                                                                  Page  1

          Date of Hearing:  January 9, 2012

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Henry T. Perea, Chair

                   AB 318 (Skinner) - As Amended:  January 4, 2012

          Majority vote.  Fiscal committee.

           SUBJECT  :  Administration of income taxes:   definition of "legal 
          holiday." 

           SUMMARY  :  Conforms California's income tax laws to the federal 
          income tax law regarding the definition of a "legal holiday" and 
          the due dates for filing income tax returns and making payments. 
           Specifically,  this bill :  

          1)Codifies the Franchise Tax Board's (FTB) authority, by 
            reference to Internal Revenue Code (IRC) Section 7503, to 
            extend the due date for filing tax returns and making 
            payments, for purposes of the Personal Income Tax (PIT) and 
            the Corporation Tax (CT) laws, if the last day to file or make 
            a payment falls on a Saturday, Sunday, or a legal holiday. 

          2)Defines the term "legal holiday" to include legal holidays 
            recognized by the federal government for filing federal tax 
            returns and making payments, including legal holidays in the 
            District of Columbia.

           EXISTING FEDERAL LAW  :

          1)Requires taxpayers that file on a calendar basis to file their 
            income tax return on or before April 15th.  

          2)Provides that, when April 15th falls on a Saturday, Sunday, or 
            legal holiday, a return is considered timely filed and 
            payments are considered timely made if filed or made on the 
            next succeeding day that is not a Saturday, Sunday, or legal 
            holiday. 

          3)Defines a "legal holiday" to include a legal holiday in the 
            District of Columbia.  Under District of Columbia law, 
            Emancipation Day, which is celebrated on April 16th, is a 
            legal holiday. 









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           EXISTING STATE LAW:

           1)Prescribes specified due dates of for filing income tax 
            returns and making payments.  

          2)Does not recognize Emancipation Day as a legal holiday. 

           FISCAL EFFECT  :  According to the FTB staff, this bill will not 
          impact state income tax revenues and will not significantly 
          impact the FTB's programs and operations.  

           COMMENTS  :   

           1)The Author's Statement.   "Under current law, when the federal 
            Emancipation Day holiday falls on the same date that income 
            tax returns and payments are due, the Internal Revenue Code 
            provides for extending the filing deadline for federal income 
            taxes - California law does not.  Each time the federal 
            Emancipation Day holiday falls on the same date that income 
            tax returns and payments are due, the Franchise Tax Board must 
            administratively change the due date for California income tax 
            documents and payments to ensure that penalties are not 
            assessed for taxpayers who file on the IRS extended deadline.  
            AB 318 adds language to the Revenue and Taxation Code to 
            define a legal holiday for California income tax purposes to 
            include those legal holidays recognized by the Internal 
            Revenue Service for federal returns."
             
          2)The Purpose of this Bill  .  This bill is sponsored by the FTB 
            to modify the filing and payment due dates to mirror federal 
            holiday due date extensions.  According to the FTB, AB 318 is 
            needed to codify the filing and payment due dates in order "to 
            eliminate taxpayer confusion when the FTB changes the due 
            dates on forms and instructions, without statutory authority, 
            when there is a federally recognized holiday that changes the 
            due date for federal income tax returns."  

           3)Background  .  Under the federal tax law, the Internal Revenue 
            Service (IRS) is statutorily authorized to extend the due 
            dates for filing returns and making payments when a due date 
            falls on a Saturday, Sunday, or a legal holiday.  The 
            definition of a "legal holiday" includes a legal holiday in 
            the District of Columbia as well as a statewide legal holiday 
            in the state where an IRS office is located.  The District of 
            Columbia celebrates Emancipation Day on April 16th, which 








                                                                  AB 318
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            falls close to the April 15th statutory due date for filing 
            most personal income tax returns and for making certain 
            tax-related payments.  

          Under California's income tax laws, a calendar-year individual, 
            partnership, or limited liability company must file the income 
            tax returns and make payments on or before April 15 following 
            the close of the calendar year.  (R&TC Section 18566).  
            Fiscal-year filers must file their tax returns and make 
            payments on or before the 15th day of the 4th month following 
            the close of the fiscal year.  The FTB has implemented 
            regulations providing for an extension of time to file returns 
            in the case where the last day for filing those returns falls 
            on a Saturday, Sunday, or other legal holiday.  (California 
            Income Tax Regulation 18566).  In that case, Regulation 18566 
            authorizes taxpayers to file returns on the day following the 
            Saturday, Sunday, or the legal holiday. 

          In California, Emancipation Day is not recognized as a legal 
            holiday.  Consequently, if Emancipation Day or any other 
            federal holiday that is not recognized in California falls on 
            the due date for filing a tax return, California and federal 
            income tax returns may have different due dates.  As noted by 
            the FTB, in the case of the April 16th Emancipation Day 
            holiday, California and the federal due dates will be 
            different eight times in the next 19 years.  

          Generally, a taxpayer needs a completed federal income return in 
            order to prepare a California income tax return.  Therefore, 
            the FTB administratively extended the due dates for filing 
            California income tax returns and making related payments to 
            correspond to the federal extended due dates.  This bill is 
            necessary to provide the FTB with the statutory authority to 
            extend those due dates, in conformity with the federal holiday 
            due date extensions.   AB 318 would provide that, if the last 
            day for filing returns falls on a Saturday, Sunday, or other 
            legal holiday, returns may be filed and payments may be made 
            on the following day without penalty.  AB 318 would allow 
            those extensions not only for filing of returns or making 
            payments, but also for making elections that are required to 
            be made, under both the PIT and CT laws, on a timely-filed 
            original return otherwise due on April 15th.  
            
           REGISTERED SUPPORT / OPPOSITION  :   









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           Support 

           Franchise Tax Board (sponsor)

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