Legal Notice 97 - 7
STATE OF CALIFORNIA
FRANCHISE TAX BOARD Legal Branch
ERNEST J. DRONENBURG, JR.
August 15, 1997
FTB NOTICE 97-7
SUBJECT: REQUEST FOR PUBLIC COMMENT WATER'S-EDGE WHITE PAPER
As requested by the Franchise Tax Board, staff has prepared a White Paper describing the problems that taxpayers and staff have encountered in complying with and administering the waters-edge provisions of the Revenue and Taxation Code. The White Paper identifies a number of problems, makes three recommendations for law changes and includes revenue estimates, and suggested statutory draft language. Staff first recommends that the current election by contract be replaced by a top tier parent election. Staff also recommends that broad authority be provided to allow perfection of elections made under the current law which are invalid owing to unintentional noncompliance with statutory requirements. If the top tier parent election recommendation is enacted, staff further recommends administrative authority be enacted to allow perfection of elections in limited circumstances.
Public written comment is invited with respect to the White Paper, including its recommendations and draft statutory language. Suggested amendments to the draft statutory language would be helpful. For copies of the White Paper and attachments or for further information regarding this notice, contact Valerie Holland at the Franchise Tax Board Legal Branch, P.O. Box 1720, Rancho Cordova, CA 95741-1720, (916) 845-3309. The White Paper and attachments are also available at website www.ftb.ca.gov.
Written comments may be addressed to Elaine Segarra, P.O. Box 1779, Rancho Cordova, CA 95741-1779 and should be submitted by September 15, 1997.