Note that the part of the law that restricted its applicability was unconstitutional. The ability to offer this tax break, period, is not. Thus, the logical re

Note that the part of the law that restricted its applicability was unconstitutional. The ability to offer this tax break, period, is not. Thus, the logical resolution would be to allow those unconstitutionally barred from receiving the benefit to file for retroactive benefits. However, this would allow pretty much any company located anywhere to file for the benefit (at least to my reading; IANAL), completely defeating the purpose of a tax law that encouraged CA businesses and potentially bankrupting the state. So: someone ignored the spirit of the law and exploited a loophole to get themselves a bigger tax break and instead broke the entire system for everyone. California was stuck between a rock (allowing for pretty much everyone to file for retroactive benefits) and a hard place (nullifying previous year benefits for those who received them). Nice job, guy.