BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2031
                                                                  Page  1

          Date of Hearing:   April 28, 2014



                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Raul Bocanegra, Chair

                    AB 2031 (Dahle) - As Amended:  April 21, 2014
           

           Majority vote.  Fiscal committee.
           
          SUBJECT  :   The Lumber Products Assessment:  small seller  
          exemption

          SUMMARY  :   Relieves small retailers from liability to collect  
          the Lumber Products Assessment (LPA) and to report to the State  
          Board of Equalization (BOE), as provided.  Specifically,  this  
          bill  :  

          1)Excludes from the definition of a "retailer" a retailer with  
            de minimis sales of qualified lumber products and engineered  
            wood products of less than $5,000 during the previous calendar  
            year. 

          2)Clarifies that the references to "feepayer" under the Fee  
            Collection Procedures Law shall include a person required to  
            pay the LPA, which includes the retailer.  
           
           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.  
           
           2)Imposes a complementary use tax on the storage, use, or other  
            consumption in this state of TPP purchased from any retailer.   
            The use tax is imposed on the purchaser, and unless the  
            purchaser pays the use tax to a retailer registered to collect  
            the California use tax, the purchaser remains liable for the  
            tax, unless the use is exempted.  The use tax is set at the  
            same rate as the state's sales tax and must be remitted to the  
            BOE.  









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          3)Imposes an LPA at the rate of 1% on a purchaser of lumber  
            products and engineered wood products to be collected by the  
            retailer at the time of sale.  Applies to sales occurring on  
            or after January 1, 2013.  

          4)Defines a "retailer" by reference to Revenue and Taxation Code  
            (R&TC) Section 6015 as:

             a)   Every seller who makes any retail sale or sales of  
               tangible personal property, and every person engaged in the  
               business of making retail sales at auction of tangible  
               personal property owned by the person or others. 

             b)   Every person engaged in the business of making sales for  
               storage, use, or other consumption or in the business of  
               making sales at auction of tangible personal property owned  
               by the person or others for storage, use, or other  
               consumption. 

             c)   Any person conducting a race meeting under Chapter 4 of  
               Division 8 of the Business and Professions Code, with  
               respect to horses which are claimed during such meeting.

          5)Provides that the LPA is due and payable to the BOE quarterly  
            on or before the last day of the month next succeeding each  
            quarterly period and requires a retailer to file a return with  
            the BOE on or before the last day of the month following each  
            quarterly period, as prescribed by the BOE. 

          6)Does not provide any type of exemption from the collection of  
            the LPA for otherwise qualified retailers that have few or no  
            sales of lumber products or engineering wood.  These retailers  
            must file zero or small dollar returns. 

           FISCAL EFFECT  :   The BOE staff estimates that this bill would  
          result in an annual revenue loss of approximately $6,000 to  
          $8,000.  The BOE staff notes, however, that purchasers would  
          still be required to report the LPA to the BOE.  

           COMMENTS  :   

           1)The Purpose of the Bill  .  According to the author, this bill  
            is needed to provide relief to small sellers of lumber  
            products by eliminating the expense of collecting and  
            reporting the LPA.  The author states that, regardless of  








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            whether a retailer has $0.01 or $100,000 in annual sales of  
            qualified lumber products, they are required to register with  
            the BOE and report the LPA on all those sales.  AB 2031 would  
            exempt retailers with de minimis annual sales of qualified  
            lumber products and engineered wood products of less than  
            $5,000 from the obligation to collect the LPA fee and report  
            to the BOE.  However, purchasers would still be required to  
            report the LPA on these products directly to the BOE. 

           2)The LPA Program  .  In 2012, the Legislature established a new  
            assessment on the sales of lumber products and engineered wood  
            products at a rate of 1% of gross receipts, on or after  
            January 1, 2013 [AB 1492 (Budget Committee), Chapter 289,  
            Statutes of 2012].  The LPA was one of the provisions in AB  
            1492 that were proposed by the timber industry and  
            incorporated by the Governor in the May Revise to reform  
            wildfire liability damages, extend the life of Timber Harvest  
            Plans (THP), and fund the timber harvest review.

          The LPA is imposed on a purchaser of a lumber product or an  
            engineered wood product for the storage, use, or other  
            consumption in California.  While the legal incident of this  
            assessment fee is placed on the purchaser, the retailers are  
            the ones required to collect the LPA at the time of sale,  
            itemizing the amount of the LPA on the sales receipts.  The  
            law allows a retailer to be reimbursed for the costs of  
            setting up the collection system from the assessment amounts  
            collected by the retailer.  

          It was estimated that AB 1492 will generate $30 million  
            annually.  As of April 11, 2013, the BOE collected a total of  
            $31,943 in LPAs. The revenues are expected to fund timber  
            harvest review, offset $15.5 million in General Fund  
            expenditures, offset timber harvest permitting fees to lower  
            the timber operator's cost of preparing a THP, pay for related  
            administrative costs, and fund forest restoration projects in  
            the state.  Funds are available, upon appropriation, for  
            administrative costs, and for purposes relating to the  
            regulatory activities of the Department of Forestry and Fire  
            Protection, and other state and local agencies involved in the  
            management of forest lands.  Funds may also be available for  
            certain grants to state and local public agencies for fire  
            protection, fire suppression and restoration activities. 

          3)LPA Collections.   Under existing law, all retailers that sell  








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            or may sell lumber products or engineered wood products are  
            required to register with the BOE and report the LPA on those  
            sales, regardless of the sales amount.  The LPA amount must be  
            separately stated on the sales receipt as a charge separate  
            from, and not included in, any other fee, charge, or other  
            amount paid by the purchaser.  According to the BOE staff,  
            during 2013 calendar year, about 29,640 businesses, with  
            approximately 39,609 retail locations, were registered with  
            the BOE as retailers required to collect the LPA.  However,  
            over 33,000 of these accounts have been closed by the BOE  
            because those retailers filed zero returns and/or were not  
            making qualified sales of wood products.  Of the remaining  
            registered accounts, approximately 605 retail locations  
            reported LPA sales of less than $5,000 for calendar year 2013.  
             According to the BOE staff, retailers that reported zero  
            sales of lumber products during 2013 calendar year will be  
            de-registered by the BOE.  

           4)The "Small Retailer" Exemption: a Slippery Slope?   According  
            to the BOE staff, in 2013, the BOE collected less than $7,000  
            in LPAs from retailers whose total sales of qualified lumber  
            and engineered wood products were $5,000 or less ("small  
            retailers").  This bill proposes to exempt small retailers of  
            that size from the requirement to collect and report the LPA  
            to the BOE.  The small retailers would, nonetheless, have to  
            track their sales of lumber products to ensure that they  
            qualify for the exemption.  It should be noted that AB 2031  
            does not waive the imposition of the LPA, since it is legally  
            levied on the purchaser of qualified lumber products.  Thus,  
            the purchaser would be required to remit the LPA to the BOE,  
            even if the retailer is legally exempt from the requirement to  
            collect an LPA.  However, this bill would create an  
            unprecedented type of relief in tax law - a relief where one's  
            tax collection obligation is waived depending on one's gross  
            sales amount.  While BOE regulations promulgated under the  
            Sales and Use Tax Law excludes from the definition of  
            "retailer" a seller who has two or fewer sales of tangible  
            personal property during any 12-month period, that exclusion  
            is not based on the total amount of the seller's gross  
            receipts.  The Committee may wish to consider whether the  
            benefits of relieving small retailers from the LPA collection  
            obligation outweigh the downside of creating a questionable  
            legal precedent for other than tax and fee programs.  The  
            Committee may also wish to consider whether small retailers,  
            if relieved from the collection obligation, should be required  








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            to notify their purchasers of the responsibility to remit the  
            LPA to the BOE. 

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          State Board of Equalization (Sponsor)

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