BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2754
                                                                  Page  1

          Date of Hearing:  April 28, 2014


                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Raul Bocanegra, Chair

            AB 2754 (Committee on Revenue and Taxation) - As Introduced:    
                                   March 24, 2014
           

           Majority vote.  Fiscal committee.
           
          SUBJECT  :  Franchise Tax Board:  administration:  dependent  
          credit:  electronic filing.

           SUMMARY  :  Requires that the dependent's tax identification  
          number be included on a return when claiming a Dependent  
          Exemption Credit, and requires a business entity that prepares a  
          return using tax preparation software to file the return  
          electronically.  Specifically,  this bill  :  

          1)Provides, beginning on or after January 1, 2015, that a  
            Dependent Exemption Credit exemption shall not be allowed  
            unless the identification number, as defined in Internal  
            Revenue Code (IRC) Section 6109, of the dependent is included  
            on the return.

          2)Provides that a taxpayer shall have the right to claim the  
            credit or refund of adjusted amounts within the statute of  
            limitation.

          3)Requires, beginning on or after January 1, 2014, that a  
            business return be filed using electronic technology if the  
            return was prepared using a tax preparation software.  The  
            return shall be filed in a manner prescribed by the Franchise  
            Tax Board (FTB).  This provision applies to returns required  
            to be filed on or after January 1, 2015.

          4)Provides that a business entity required to file a return  
            electronically under this section may annually request a  
            waiver of the requirement from the FTB for a taxable year.   
            The FTB may grant the waiver if it determines that the  
            business entity is unable to comply with the requirements due  
            to technology constraints, where compliance would result in  
            undue financial burden, or due to circumstances that  








                                                                  AB 2754
                                                                  Page  2

            constitute reasonable cause, and not willful neglect.

          5)Provides that a business entity that is required to  
            electronically file a return and fails to comply shall be  
            subject to a penalty of $500 for each failure unless the  
            failure is due to reasonable cause, and not willful neglect.   
            This provision applies to returns filed for taxable years  
            beginning on or after January 1, 2016.

          6)Provides that the FTB shall conduct a robust education program  
            advising businesses of the new electronic filing requirements  
            and shall liberally interpret and grant waivers of the penalty  
            to minimize unnecessary adverse impacts to businesses that  
            experience difficulty complying with these requirements.

          7)Defines an "acceptable return" as an original or amended  
            return that is required to be filed by a business entity other  
            than the return for unrelated business taxable income.

          8)Defines a "business entity" as a corporation, including an "S"  
            corporation, an organization exempt from tax, a partnership,  
            or a limited liability company.

          9)Defines "tax preparation software" as any computer software  
            program used to prepare an acceptable return or for use in tax  
            compliance.

          10)Defines "electronic technology" to include, but is not  
            limited to, the Internet, cloud computing, or an electronic  
            information delivery system.

          11)Defines "technology constraints" as an inability of the tax  
            preparation software to electronically file the acceptable  
            return as required by this section as a result of the complex  
            nature of the return or inadequacy of the software.

           EXISTING FEDERAL LAW  :
           
          1)Mandates e-filing for the following:

             a)   Large corporations with $10 million or more in total  
               assets;

             b)   A partnership with more than 100 partners;









                                                                  AB 2754
                                                                  Page  3

             c)   Certain large tax-exempt organizations with total assets  
               of $10 million; 

             d)   Private foundations and charitable trust regardless of  
               their size; and,

             e)   Tax preparers that file at least 250 returns, including  
               income tax returns, exempt organization returns,  
               information returns, excise tax returns, and employment tax  
               returns.

          2)Allows exceptions and hardship waivers from the e-filing  
            requirement.  A taxpayer may request a waiver if the taxpayer  
            is unable to meet e-filing requirements due to technology  
            constraints or where compliance with the requirements would  
            result in undue financial burden on the taxpayer.

          3)Provides that a failure to file penalty is generally five  
            percent of the tax owed for each month, up to a maximum of  
            25%.  If the return is over 60 days late, the minimum penalty  
            for late filing is the lesser of $135 or 100% of the tax owed.

          4)Requires that the (Taxpayer Identification Number) TIN of the  
            dependent be included on the federal return to take advantage  
            of the dependent exemption.

          5)Provides that a TIN is an identification number used by the  
            Internal Revenue Service (IRS) in the administration of tax  
            laws.  A social security number is issued by the Social  
            Security Administration whereas all other TINs are issued by  
            the IRS.  

           EXISTING STATE LAW  :

          1)Requires income tax preparers who prepare more than 100  
            California individual income tax returns annually or prepare  
            one or more using tax preparation software to e-file all  
            personal income tax returns.

          2)Imposes a failure to e-file penalty of $50 per return filed on  
            paper that should have been e-filed, unless it is shown that  
            the failure to e-file is due to reasonable cause and not due  
            to willful neglect.

          3)Prohibits the disallowance of the Dependent Credit if the  








                                                                  AB 2754
                                                                  Page  4

            return lacks a TIN.  This provision was added in 1997  
            following the IRC change that required the TIN of dependents  
            on the personal income tax return in response to concerns  
            about obtaining a TIN for newborns in time to include the TIN  
            on the return.

           FISCAL EFFECT  :   The FTB estimates that the e-filing requirement  
          will not have an impact on General Fund (GF) revenues.  The FTB  
          estimates that the inclusion of dependent taxpayer  
          identification numbers on tax returns will increase GF revenues  
          by $10 million in fiscal year (FY) 2014-15, $10 million in FY  
          2015-16, and $11 million in 2016-17.

           COMMENTS  :   

           1)The Purpose of E-Filing  .  If the return of a business entity  
            is prepared using tax preparation software, but a paper return  
            for that business entity is filed, the FTB must process that  
            return using costly manual data capture methods that lack the  
            accuracy and efficiency associated with e-filing.  This bill  
            would require a business entity that files an acceptable  
            return that was prepared using tax preparation software to  
            file the return by electronic technology in a form and manner  
            prescribed by the FTB, unless the business entity, upon  
            request, is granted a waiver.  Requiring a business entity to  
            e-file a return when a taxpayer uses tax preparation software  
            would result in the FTB processing returns more quickly, which  
            would expedite approved refunds and utilize cost-effective  
            technology to meet operational goals.  E-filing a return  
            lowers the initial cost of processing returns.  The FTB  
            estimates that the average cost to the department to process a  
            business entity paper filed return is $6 (includes complex and  
            smaller taxpayer returns), as opposed to $0.36 (primarily  
            based on smaller taxpayer returns) for an e-filed return.  

           2)The Purpose of Requiring a TIN  .  Not requiring a TIN for each  
            dependent be included on the state tax return precludes the  
            department from validating Dependent Exemption Credits during  
            return processing, which delays the correction of erroneous or  
            duplicated dependent credits and increases the cost of  
            correcting these errors for taxpayers and the department.   
            This bill would allow the FTB to confirm that a dependent's  
            TIN is used only once, which would increase the integrity of  
            the returns, reduce inaccurate returns, and erroneous  
            dependent credits.  This bill would also increase the  








                                                                  AB 2754
                                                                  Page  5

            timeliness of the FTB's compliance efforts, and decrease the  
            amount of incorrect refunds issued to taxpayers.   
            Additionally, this bill would allow the FTB to create an  
            automated versus manual method for examining dependent credits  
            that could reduce departmental cost.
             
          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Franchise Tax Board (Sponsor)

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