Submitted Comment Name Joe Collins Affiliation N/A Subject Clarification on revenue measurement Message I am writing to seek clarification regarding the specific nature and scope of how revenues should be measured as outlined in Senate Bill No. 253 and Senate Bill No. 261, as amended by SB 219. Senate Bill No. 253 defines a “reporting entity” as “a corporation, partnership, limited liability company, or other business entity formed under the laws of the state, the laws of any other state of the United States or the District of Columbia, or under an act of the Congress of the United States” with total annual revenues in excess of one billion dollars ($1,000,000,000) that “does business in California”. Additionally, Senate Bill No. 261 defines a “covered entity” as a similar business entity with total annual revenues exceeding five hundred million dollars ($500,000,000) that also that “does business in California”. Specifically, does the revenue measurement pertain to California-only generated revenues, U.S. generated revenues, or global revenues? For subsidiaries identified as 'doing business in California,' should revenue be measured on a consolidated basis for those entities, consolidated U.S. entities, or global group entities? Any additional considerations, guidance and clarity regarding revenue measurement within the final regulations would be appreciated. File Upload (i.e., Attachments): N/A
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