BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2332
                                                                  Page  1

          Date of Hearing:  May 7, 2012

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Henry T. Perea, Chair
                   AB 2332 (Monning) - As Amended:  April 12, 2012

          Majority vote.  Tax levy.  Fiscal committee.  
           
          SUBJECT  :  Income taxes:  deductions:  disaster losses:  County 
          of Santa Cruz

           SUMMARY  :  Provides that any losses sustained in the County of 
          Santa Cruz as a result of the severe storms that occurred in 
          March 2011 (2011 Storms) may, at the taxpayer's election, be 
          taken into account for the taxable year immediately preceding 
          the taxable year in which the disaster occurred.  Specifically, 
           this bill  :  

          1)Provides that Internal Revenue Code (IRC) Section 165(i) shall 
            apply to any losses sustained in the County of Santa Cruz as a 
            result of the 2011 Storms.  

          2)Provides that the election under IRC Section 165(i) may be 
            made on a return or amended return filed on or before the due 
            date of the return, determined with regard to extension, for 
            the taxable year in which the disaster occurred.  

          3)Provides that, unless otherwise specified, any law that 
            suspends, defers, reduces, or otherwise diminishes the 
            deduction of a net operating loss (NOL) shall not apply to a 
            NOL attributable to losses described above.   

          4)Takes immediate effect as a tax levy.  

           EXISTING LAW  :

          1)Allows individual and corporate taxpayers to utilize NOLs to 
            offset their tax liabilities.  For NOLs incurred in taxable 
            years beginning on or after January 1, 2008, existing law 
            provides a carryover period of 20 years. 

          2)Allows NOLs attributable to taxable years beginning on or 
            after January 1, 2013, to be carrybacks to each of the 
            preceding two taxable years, as provided.  









                                                                  AB 2332
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          3)Disallows the deduction for NOLs and NOL carryovers in the 
            2008 to 2011 taxable years for specified taxpayers.  

           FISCAL EFFECT  :  The Franchise Tax Board estimates that this bill 
          would reduce General Fund (GF) revenues by $2,000 in fiscal year 
          (FY) 2011-12, and would increase GF revenues by $1,000 in both 
          FY 2012-13 and FY 2013-14.  

           COMMENTS  :

          1)The author has provided the following statement in support of 
            this bill:

               Between March 15 and 27, 2011, California was struck by a 
               devastating storm, destroying and damaging public 
               facilities and private property throughout the state.  
               Santa Cruz County sustained $15 million in damage, 30 
               percent of the statewide total.  In order to provide timely 
               relief for those who have sustained damage or loss as a 
               result �of] the severe March 2011 Storm, it is necessary 
               that AB 2332 take effect immediately.  

          2)Committee Staff Comments

              a)   The 2011 Storms  :  In March 2011, the County of Santa 
               Cruz was struck by a severe storm that brought heavy rain, 
               high winds, and flooding, damaging or destroying both 
               public facilities and private property throughout the 
               county.  The county sustained roughly $15 million in 
               damage.  

             In April 2011, Governor Brown issued an Emergency 
               Proclamation for this storm and asked the federal 
               government to declare the event a major disaster.  
               California's request to the Federal Emergency Management 
               Agency was denied, along with the state's subsequent appeal 
               of this decision.   

             b)   Casualty losses vs. disaster losses  :  Under both federal 
               and state law, a casualty loss is defined as the damage, 
               destruction, or loss of property resulting from an 
               identifiable event that is sudden, unexpected, or usual.  A 
               disaster loss, on the other hand, occurs when business or 
               personal property is partially or completely destroyed by a 
               fire, storm, flood, or other natural event in an area 








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               declared to be a disaster by the President of the United 
               States.  
              
                Individuals with non-business casualty or disaster losses 
               that are unreimbursed may deduct such losses to the extent 
               that each loss exceeds $100 and aggregate net losses for 
               the taxable year exceed 10% of adjusted gross income.  To 
               the extent that a casualty or disaster loss contributes to 
               a NOL, that loss is allowed a 20 year carry forward 
               treatment.  In other words, 100% of the NOL may be carried 
               over for up to 20 taxable years.

              c)   Special tax treatment provided automatically for 
               disaster losses  :  In the case of disaster losses, a 
               taxpayer may elect to file an amended return to deduct the 
               loss in the taxable year prior to the taxable year in which 
               the disaster loss actually occurred, resulting in an 
               expedited refund.  This election may be made for any 
               Presidentially-declared disaster prior to passage of any 
               state legislation allowing this treatment because 
               California conforms to federal disaster tax law treatment.  
               The election is not available, however, for a 
               "Governor-only" declared disaster, unless special state 
               legislation is enacted. 

               For disasters that were the subject of a Governor's 
               proclamation, but not the subject of a Presidential 
               disaster declaration, enactment of state law identifying a 
               specific event as a disaster for state tax law purposes 
               authorizes effected taxpayers to elect to deduct disaster 
               losses on the return for the prior taxable year. 

              d)   What would this bill do?  :  This bill would allow 
               taxpayers who suffered losses as a result of the 2011 
               Storms to elect to file an amended return for the prior 
               taxable year.  Thus, taxpayers would be able to claim the 
               disaster losses earlier than otherwise permitted, resulting 
               in an expedited refund.  Specifically, a taxpayer would 
               have until the extended due date for the 2011 taxable 
               year's return to elect to file an amended return for the 
               prior taxable year to deduct the disaster losses in the 
               prior year.  This bill would also provide limited 
               protection from future NOL suspension legislation for 
               losses sustained in the 2011 Storms.  









                                                                  AB 2332
                                                                  Page  4

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          None on file

           Opposition 
           
          None on file
           
          Analysis Prepared by  :  M. David Ruff / REV. & TAX. / (916) 
          319-2098