AB 1519 California Assembly · 2025-2026 Regular Session

Taxation: tax liability: collections.

Summary

Under existing tax law, once a tax liability becomes due and payable, as defined, a statutory lien arises for that amount upon all real and personal property belonging to that taxpayer. Existing law establishes a statute of limitations on collections of those liabilities to limit the collection period to 20 years beginning from the date that the latest tax liability for a taxable year or the date any other liability that is not associated with a taxable year becomes due and payable, and thereafter extinguishes that liability. Existing law defines "tax liability" as a liability imposed under the Personal Income Tax Law, the Corporation Tax Law, or the laws related to the administration of franchise and income tax laws, including any additions to tax, interest, penalties, fees, and any other amounts relating to the imposed liability. This bill would redefine "tax liability" to exclude interest, penalties, costs, or fees, except a specified fee on limited liability companies, relating to the assessment of tax, any other amounts relating to the imposed liability, and any additions to tax. The bill would require the collection period for interest, penalties, costs, or fees that may accrue with a particular tax liability to lapse at the same time as the related tax liability.

Bill status passed both 4 of 5 stages cleared

Introduction

Mar 2025

Committee Review

Aug 2026

Assembly Passage

Apr 2025

Senate Passage

Aug 2026

Governor

Introduced Mar 13, 2025 Last action Aug 27, 2026

Maddy AI version diff · 2 comparisons

What changed between versions

04/28/26 - Amended Senate → AB1519 · 2 edits

MINOR

The final enrolled version of AB 1519 removed the employer notification requirements related to the IRS Direct File program (amendments to Sections 19852, 19853, and 19854 of the Revenue and Taxation Code). The bill now only contains the tax collection statute of limitations changes in Section 19255, which redefine 'tax liability' to exclude interest, penalties, costs, and fees (except the LLC fee), and require those amounts to lapse at the same time as the underlying tax liability.

Scope change

The bill's scope was narrowed significantly. It previously covered two distinct policy areas: (1) tax collection limitations and (2) employer notification requirements for Direct File. The final enrolled version covers only the tax collection limitations changes, dropping the Direct File employer notification mandate entirely.

SCOPE

Removed all amendments to Sections 19852, 19853, and 19854 of the Revenue and Taxation Code that would have required employers to include information about the IRS Direct File program in their annual notifications to employees about tax filing assistance and antipoverty tax credits. This provision was set to take effect January 1, 2026.

The bill's stated purpose was narrowed from amending five code sections (19852, 19853, 19854, and 19255) to amending only Section 19255.

03/13/25 - Introduced → 04/28/26 - Amended Senate · 6 edits · Apr 28, 2026

MODERATE

The Senate amendment adds an entirely new section (Section 1) amending Revenue and Taxation Code Section 19255, which governs the statute of limitations on tax collections. The new provision redefines 'tax liability' to exclude interest, penalties, costs, fees, and additions to tax from the 20-year collection period, makes expiration of that period mandatory rather than permissive, and ties the collection window for ancillary amounts to the underlying tax. The original EITC/Direct File employer notification provisions are retained but omitted from this version's text. This matters because it significantly limits how long the state can pursue old tax debts and their accumulated interest and penalties.

SCOPE

A new Section 1 amending R&TC Section 19255 was added, introducing a redefined statute of limitations framework for tax collections that did not exist in the introduced version.

New suspension provisions are added for the collection limitation period, covering bankruptcy cases (plus six months), installment payment agreements, combat zone service, presidentially declared disasters or terroristic/military actions, and any other period where collection is suspended by operation of law.

DEFINITION

'Tax liability' is redefined to exclude interest, penalties, costs, fees (except the LLC fee under Section 17942), and additions to tax. Previously the definition included all of these amounts within the 20-year collection period.

ENFORCEMENT

The language changes from 'the Franchise Tax Board may collect' to 'shall not collect' after 20 years, making the expiration of the collection period mandatory rather than permissive. The FTB is also required to release, withdraw, or terminate any actions taken to collect an uncollectible liability.

REQUIREMENT

A new provision requires that the collection period for interest, penalties, costs, or fees accruing with a particular tax liability shall lapse at the same time as the related tax liability, preventing the state from continuing to collect ancillary amounts after the underlying tax has expired.

TIMELINE

The amended Section 19255 is made retroactive, applying on and after July 1, 2006, to any liability due and payable before, on, or after that date.

Floor votes · Senate Aug 20, 2026 · Assembly Apr 28, 2025

How they voted

39–0

Passed · 1 other

Total votes 40

Aug 20, 2026

D Democratic30

29 Yea 1

96% Yea

R Republican10

10 Yea

100% Yea

Vote distribution

All Yea All Nay Mixed No data

Full legislative history

Actions timeline

Total actions

Key actions

Committee

Amendments

Aug 27, 2026

Lower · Passed

Senate amendments concurred in. To Engrossing and Enrolling. (Ayes 77. Noes 0.).

lower

Aug 27, 2026

Lower · Passed

From committee: That the Senate amendments be concurred in. (Ayes 7. Noes 0.) (August 27).

lower

Aug 24, 2026

Committee

Re-referred to Com. on REV. & TAX. pursuant to Assembly Rule 77.2.

lower

Aug 20, 2026

Introduced

In Assembly. Concurrence in Senate amendments pending.

lower

Aug 20, 2026

Upper · Passed

Read third time. Passed. Ordered to the Assembly. (Ayes 39. Noes 0.).

upper

Aug 13, 2026

Upper · Passed

From committee: Do pass. (Ayes 7. Noes 0.) (August 13).

upper

Aug 3, 2026

Committee

In committee: Referred to APPR. suspense file.

upper

Jun 24, 2026

Upper · Passed

From committee: Do pass and re-refer to Com. on APPR. (Ayes 4. Noes 0.) (June 24). Re-referred to Com. on APPR.

upper

Apr 28, 2026

Introduced

From committee chair, with author's amendments: Amend, and re-refer to committee. Read second time, amended, and re-referred to Com. on REV. & TAX.

upper

May 7, 2025

Committee

Referred to Com. on REV. & TAX.

upper

Apr 28, 2025

Lower · Passed

Read third time. Passed. Ordered to the Senate. (Ayes 76. Noes 0. Page 1321.)

lower

Apr 22, 2025

Lower · Passed

From committee: Do pass. To Consent Calendar. (Ayes 7. Noes 0.) (April 21).

lower

Mar 24, 2025

Committee

Referred to Com. on REV. & TAX.

lower

Mar 14, 2025

Lower · Passed

From printer. May be heard in committee April 13.

lower

1 primary · 0 co-sponsors