State Tax Day - Current, S.6, California—Corporate, Personal Income Taxes: "Tax Liability" Redefined for Purposes of Statute of Limitations on Collections, (Sep 29, 2026)
California has redefined the term "tax liability" for purposes of the the 20-year statute of limitations for Franchise Tax Board collection activities. Under the revised definition, "tax liability" does not include interest, penalties, costs, or fees (except the limited liability company fee) relating to the assessment of tax. Thus, the imposition of any of these items will no longer have an impact on the determination of the 20-year statute of limitations on the underlying tax liability. The collection period for interest, penalties, costs, or fees that may accrue with a particular tax liability will lapse at the same time as the collection period for the related tax liability.
A.B. 1519, Laws 2026, effective January 1, 2027