Regarding the adjustment made by SBX1 28 to AB 1452 with this language:

SEC. 8. (a) For purposes of applying Section 23663 of the Revenue and Taxation Code, as added by Assembly Bill 1452 of the 2007-08 Regular Session, any limitations on allowance of any credit against the “tax” that would apply to the assigning taxpayer in the absence of an assignment shall also apply to the same extent to the allowance of that assigned credit against the “tax” of the eligible assignee.

In my previous post I asked:

One question that arises regarding this new language in SBX1 28 is, does “shall apply to the same extent” mean that credits generated in a particular zone must be used only against tax generated in that same zone even if the credits are assigned to an affiliate with tax generated in a different zone?

I have since received a tentative response from a representative with FTB, “yes.” In other words, the assignee entity would have to have income from the identical Enterprise Zone as the assigning entity in order to make use of tax credits.  I was also told to expect written guidance from FTB on this issue in the near future.

Let me know if you can think of a case where this would help someone.