BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 680
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          SENATE THIRD READING
          SB 680 (Wolk)
          As Amended May 14, 2013
          Majority vote 

           SENATE VOTE  :36-0  
           
           JUDICIARY           10-0                                        
          
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          |Ayes:|Wieckowski, Wagner,       |     |                          |
          |     |Alejo, Chau, Dickinson,   |     |                          |
          |     |Garcia, Gorell,           |     |                          |
          |     |Maienschein, Muratsuchi,  |     |                          |
          |     |Stone                     |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
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           SUMMARY  :  Sponsored by the Department of Justice, this  
          non-controversial bill logically seeks to close an inadvertent  
          loophole in existing law that requires tobacco manufacturers not  
          party to the Master Settlement Agreement (MSA) to make payments  
          into escrow for their sales in California.  Specifically,  this  
          bill  :  
           
           1)Revises, for the purpose of calculating the amount a tobacco  
            product manufacturer is required to place in the qualified  
            escrow account, the definition of "units sold" to specify that  
            it is the number of cigarettes sold to a consumer in the state  
            by the applicable manufacturer, regardless of whether the  
            state excise tax was due or collected.

          2)Excludes from the definition of "units sold" any cigarettes: 

             a)   Sold on federal military installations;

             b)   Sold by a Native American tribe to a member of that  
               tribe on that tribe's land; or 

             c)   That are otherwise exempt from state excise tax pursuant  
               to federal law.

           EXISTING LAW implements the terms of the tobacco litigation MSA,  
          which grants legal immunity for past deceptive business  








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          practices to major tobacco manufacturers in exchange for certain  
          voluntary advertising restrictions and annual settlement  
          payments to states.  

           FISCAL EFFECT  :  None
           
          COMMENTS  :  This non-controversial bill, sponsored by the  
          Department of Justice, logically seeks to close an inadvertent  
          loophole in existing law that requires tobacco manufacturers not  
          party to the Master Settlement Agreement (MSA) to make payments  
          into escrow for their sales in California.  Existing law  
          currently inadvertently allows these manufacturers to avoid  
          making such payments for cigarettes that are unlawfully sold  
          without payment of state excise taxes.  According to the  
          sponsor, some non-signatory tobacco manufacturers are selling  
          large quantities of cigarettes through unlicensed distributors  
          and channels, such as tribal smoke shops and over the Internet,  
          where state tax evasion is prevalent and state-level monitoring  
          difficult.  This practice reduces the amount of funds available  
          to satisfy potential liabilities, fuels the sale of cheap  
          cigarettes which harms public health, and gives these  
          non-signatory manufacturers an unfair cost advantage over the  
          non-signatory manufacturers that do not rely on these  
          distribution channels and the tobacco manufacturers that  
          participate in the MSA.  

          In support, the author states:   
           
               Existing law requires tobacco manufacturers that did  
               not join the tobacco Master Settlement Agreement (MSA)  
               to make deposits into an escrow account as security  
               for certain potential liabilities to the State  
               (sections 104555 through 104558 of the Health and  
               Safety Code).  The amount of these deposits is based  
               on the non-signatory manufacturer's sales in  
               California, as measured by state excise taxes  
               collected on those sales.  This method of measuring  
               escrow obligations exempts sales that evade state  
               excise taxes, effectively rewarding the non-signatory  
               manufacturers for tax-evaded sales.

               Some non-signatory manufacturers are selling large  
               quantities of cigarettes through channels such as  
               tribal smoke shops and the internet where state tax  








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               evasion is prevalent.  This practice reduced the  
               amount of funds available to satisfy potential  
               liabilities, fuels the sale of cheap cigarettes which  
               harm public health, and gives the non-signatory  
               manufacturers an unfair cost advantage over  
               non-signatory manufacturers that do not rely on these  
               distribution channels and over signatories to the MSA  
               which make settlement payments in lieu of escrow  
               deposits.  

               The solution to this problem [is to amend] existing  
               law to require non-signatory manufacturers to make  
               deposits on all cigarettes sold in California that are  
               not exempt from state tax pursuant to federal law.   
               Non-signatory manufacturers would not be required to  
               make escrow deposits for sales which federal law  
               prohibits California from taxing, such as sales to  
               federal military installations and tribal sales to  
               tribal members.  The Attorney General's Office would  
               be responsible for assuring that the non-signatory  
               manufacturers make escrow deposits on the larger  
               volume of their sales through administrative action  
               and/or litigation against non-compliant manufacturers.  
                Closing the tax evasion loophole in existing law  
               would afford California greater security for  
               unreleased tobacco liabilities, promote public health,  
               and eliminate unfair competition.  

               This bill amends the Health and Safety Code to close  
               this tax-evaded sales loophole, requiring  
               non-signatory tobacco manufacturers to pay escrow on a  
               broader base of sales in the State, including all  
               sales on which state excise tax could be collected  
               under federal law.    

          On November 23, 1998, a $206 billion settlement was reached  
          between California, 45 other states, the District of Columbia,  
          Puerto Rico, and three territories, on the one hand, and five  
          major cigarette American cigarette manufacturers, concerning  
          antitrust, consumer protection, and health-related litigation  
          claims pending against the major tobacco companies at the time.   
          The resulting MSA placed significant limitations on  
          tobacco-related advertisements by tobacco companies and promised  
          multi-billion dollar annual payments to the states.  At the time  








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          of the settlement, California was projected to receive  
          approximately $25 billion in settlement funding through 2025.   
          As part of the agreement, the states dropped their lawsuits  
          against the named tobacco companies and agreed to impose similar  
          settlement terms via state law on those tobacco companies that  
          elected not to join the MSA.  

          California implemented the relevant terms of the MSA against  
          non-signatory tobacco companies, in part, by enacting the Model  
          Escrow Statute, which required these non-signatories to make  
          annual payments into a state-held escrow account based on the  
          total number of cigarettes sold to California consumers as  
          measured by state excise taxes collected on the sales.  (SB 822  
          (Escutia), Chapter 780, Statutes of 1999), codified at Health  
          and Safety Code Section 104555 et seq.)  The implementing  
          statute specified that funds held in the escrow account would be  
          used to pay judgments or settlements on any claim released by  
          the state against the non-signatory tobacco manufacturers, or  
          would be released back to the manufacturers under certain  
          circumstances.  The statute also authorized the California  
          Attorney General to enforce its terms, and to bring a civil  
          action on behalf of the state against any tobacco product  
          manufacturer that failed to place the mandated funds into the  
          escrow account.  

          Through its enforcement activities, the Attorney General's  
          Office has found that certain manufacturers are avoiding this  
          obligation to contribute to the tobacco settlement escrow  
          account by selling tax-evaded cigarettes in the state.   
          According to the Attorney General:

               This is a significant problem as the market for  
               tax-evaded product is large and growing.  In 2011, the  
               most recent year for which data is available, more  
               than 11.6 billion cigarettes were sold in the United  
               States without state excise tax being paid.  Many of  
               those tax-evaded cigarettes are sold by tribal  
               manufacturers through tribal distribution channels  
               operating outside the reach of State taxing  
               authorities.  In recent years, the Attorney General's  
               Office has been involved in a number of lawsuits  
               against tribal retailers and distributors purchasing  
               cigarettes through these tribal distribution channels.  
                In one recent case, the Attorney General found that  








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               over the course of four years, more than 300 million  
               tax-evaded cigarettes had been sold by a single tribal  
               distributor.  People v. Huber, DR 110232 (Humboldt  
               County Supreme Court 2011).  Had those cigarette sales  
               been subject to the States' Escrow Statute, more than  
               $5.5 million dollars in escrow would have been owed on  
               those sales alone.   


           Analysis Prepared by  :    Drew Liebert / JUD. / (916) 319-2334 


                                                                FN: 0001288