California: Penalties and Other Compliance Provisions in Assembly Bill 2498 (Proposed Amnesty Bill‪)‬

August 5, 2010 On August 5, 2010, Tax Executives Institute submitted the following comments to the Committee on Revenue and Taxation of the California State Senate on Assembly Bill 2448, which would impose strict liability penalties on taxpayers participating in so-called abusive tax avoidance transactions, adopt the recent federal codification of the economic substance doctrine, establish a "tax amnesty" program (with attendant penalties), and make other changes affecting taxpayers and practitioners. The letter was submitted under the aegis of TEI's State and Local Tax Committee, whose chair is Cathleen Stevens of Brunswick Corporation. Fellow Committee member Tov B. Haueisen of General Electric Company contributed materially to the preparation of the submission. Daniel B. De Jong, TEI Tax Counsel, is the legal staff liaison to the State and Local Tax Committee and coordinated the preparation of the comments.