Taxation
Ca. Tax Lawyer VOLUME 34, 2025 ANNUAL ISSUE
Content
- 2024-2025 California Lawyers Association Tax Section Executive Committee
- 2025 Annual Award Winners
- By the Tax Section Members
- California's Anti-ing Trust Statute Comes With Strange Drafting Choices, Planning Opportunities, Landmines, and Apparent Errors
- Ctl Prize For Excellence In Writing
- Editors' Note: a New Way Forward
- From the Chief Counsels
- Government Contributions To Capital May Still Qualify For Exclusion From State Income Tax
- Inside This Issue
- Local Tax Sharing Agreements: a Constitutional Critique
- Managing Ftb Audits of International Taxpayers
- Message From the Chair
- Minutes From the 2025 Meeting of Eagle Lodge West
- Rational Basis or Broad Discretion: Legal Standards Governing Cdtfa Interpretations
- Table of Contents
- High Liability
HIGH LIABILITY
COMPARING PERSONAL RESPONSIBILITY REGULATIONS FOR UNPAID CANNABIS TAX AND UNPAID SALES AND USE TAX
Written by the SALT Committee
INTRODUCTION
On June 30, 2022, Governor Gavin Newsom approved Assembly Bill No. 195.1 The bill added new sections to the California Revenue and Taxation Code, including § 34015.2, which imposes personal liability for unpaid cannabis tax. Any California tax practitioner who reads § 34015.2 may feel déjà vu. The wording of the statute largely mirrors another personal liability law which has been around for decades, namely Revenue and Taxation Code § 6829. Both statutes allow the State of California to collect the unpaid tax a business still owes the State after it terminates. The question becomes: from whom can the state collect this unpaid tax?