Tax Commission:
Many Questions About Proposed Business Net Receipts Tax Still Unanswered After Two Workshops

The Commission on the 21st Century Economy held a workshop August 28 at the University of California at Los Angeles campus to continue the discussion of the proposed Business Net Receipts Tax (BNRT). The meeting came on the heels of an August 26 workshop in San Francisco and may set the stage for the next full commission meeting, scheduled for September 10 at UCLA. (The commission also has tentatively scheduled a meeting for September 14.)

(Cal-Tax: While the agenda for the commission's final meeting does not include any specifics, the Calbuzz.com blog reported September 3 that Commission Chairman Gerald Parsky "has pledged that his group's complex proposals will be available in draft bill form for public consumption 72 hours before the commission's next meeting on September 10." However, as of 48 hours before the meeting, the only language available was for Commissioner Fred Keeley's proposal to double the state's gas tax.)

At the August 28 workshop, only six of 14 commissioners (Chairman Parsky and commission members Ruben Barrales, Christopher Edley Jr., John Cogan, Curt Pringle and Jennifer Ito) were present to discuss the proposed BNRT. However, more outsiders participated as panelists at the Los Angeles meeting than in San Francisco.

Panelists included Russell Goldsmith, chairman and chief executive officer of City National Bank; Mike Rockenbach, chief financial officer of Emulex; Eric Miethke, representing the Motion Picture Association of America; Jim Euphrat, tax manager for NASSCO GD; Jeff Barnett, vice president for taxes for Edison International; Marty Keller, the governor's appointed director of the California Office of Small Business Advocate; Greg Lippe, managing partner at Lippe, Hellie, Hoffer & Allison LLP; and Hatef Behnia, tax partner for Gibson, Dunn & Crutcher.

Commission Chairman Gerald Parsky opened the hearing by reiterating that a transition period for the BNRT is being contemplated. He said the BNRT may begin in 2011-12 and be phased in over five years. The plan would be to gradually phase out the corporate income tax and reduce personal income tax rates while phasing in the BNRT.

The ultimate rate for the BNRT still has not been revealed. (Cal-Tax: This is very troubling. The proposal is moving closer and closer to a legislative vote, but a thorough economic assessment cannot be conducted unless the tax rate – a critical factor for any tax – is disclosed.) Under Mr. Parsky's plan, corporate income tax and PIT rates would be reduced over five years, while the BNRT rates would increase. This proposal has caused some to be skeptical that the BNRT could be phased in, but the corporate and personal income taxes might not be phased out or reduced as promised.

The first panelist was Mr. Goldsmith of City National Bank. He suggested that banks should receive differential treatment under the BNRT due to their business model, in which money is equivalent to goods, and interest is equivalent to rents received for those goods. He stated that any tax structure that includes gross receipts also should contemplate interest income and expense (interest income should be included in gross receipts and credit losses and risk should be deducted as costs).

Mr. Goldsmith also said that disallowing deductions for employee compensation would discriminate against labor-intensive companies, including banks, that succeed as a result of highly compensated employees. "If the new tax system makes hiring people more difficult, then it is harder to grow and create jobs," he said.

The need to preserve venture capital in California was another of Mr. Goldsmith's concerns. He mentioned that start-ups endure a number of unprofitable years, and that this should be taken into account when crafting a new tax structure.

Mr. Goldsmith stated that the number-one rule should be, "Do no harm." Consistent with that principle, he asked commissioners to consider several questions: How would the new tax structure impact the tax liability of California industry? Would the new tax structure hurt the business climate? Would the new tax structure hurt job creation? How would the new tax structure impact prices and competition?

Mr. Parsky concluded the discussion by admitting that applying the BNRT to banks is very complicated, and he suggested that examples be developed to demonstrate how a BNRT would affect banks.

Mr. Miethke provided testimony on how the BNRT would impact the movie industry in California. He voiced several concerns and questions:

·         The BNRT has a built-in incentive to outsource and offshore, which is inconsistent with California's efforts to encourage in-state film production.

·         The BNRT's inclusion of "tax havens" in the apportionment formula could create issues with trading partners.

·         The BNRT may be unconstitutional, due to issues surrounding economic nexus.

·         The BNRT would be tough on start-up companies without a deduction for interest payments or net operating losses.

·         The BNRT would increase the cost of production in California, as small companies that provide specialty services that aren't currently taxed would be subject to the BNRT.

·         What would happen to the movie production tax credit?

·         How will capital assets be amortized?

·         The local share of sales tax would still be as high as 4.75 percent in some districts.

·         Concerns regarding business vs. nonbusiness income and interstate and intrastate apportionment would continue under the new system.

·         What happens to tax credits and NOLs at the end of the phase-in of the BNRT?

·         How would deferred gains be treated?

In response to Mr. Miethke's concerns, Mr. Pringle noted that even if the local share of sales tax remains at 4.75 percent, it still would be a large reduction from the current 10.75 percent in the worst-case scenario. Mr. Pringle did not seem troubled that the BNRT would create winners and losers.

Mr. Barnett of Edison International said that since interest expense would not be deductible under the BNRT, it would have a significant impact on capital-intensive companies. Also, he mentioned that Edison has more than 16,000 employees – a $4.5 billion labor expense. He indicated support for deductibility of employer benefit costs. He also questioned whether five years is sufficient to carry forward tax assets acquired prior to the transitional period, and expressed a desire to know the BNRT rate, as a small change in rate would have a large impact when applied to a large base.

In response, Phil Spillberg of the Department of Finance stated that employee health insurance costs would be deductible under the BNRT.

Mr. Pringle stated near the end of the hearing: "Most businesses will be paying more. Our job is not to look at any of them in isolation. … I don't feel a major momentum away from the BNRT just because business is concerned about it."

Ms. Ito, a Democratic appointee to the commission, said she sees "an incentive to go to independent contractors" under the BNRT.

Cal-TaxReports, September 8, 2009

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