MFA submitted a short comment letter to the San Francisco Office of the Treasurer & Tax Collector. The letter advocated that the Tax Collector:
- Address the administrative challenges raised by taxpayers before finalizing its proposed regulations (including those challenges MFA raised to the California Franchise Tax Board, which MFA appended to this letter)
- Wait to finalize its proposed regulations until the California Franchise Tax Board adopts its currently proposed regulations, as a matter of statutory obligation and sound tax administration
- Provide for a prospective effective date
