Continuing to kowtow to organized labor, California Governor Gavin Newsom signed a new FY 2023 state budget into law earlier this month that includes an opportunity to enact the Workers Tax Fairness Credit, an unprecedented income tax credit for union members who pay dues to union organizations. Although Newsom has already been praised by labor leaders for the tax credit, it remains to be seen whether workers will actually be able to take the credit as it is contingent upon future legislative appropriations. Notwithstanding that ‘silver lining’, the mere fact that such a tax credit has been incorporated into the state budget does not bode well bode the future treatment of small business interests as it relates the ongoing push for unionization with the QSR and fast food industry. And, to that end by way of update, we noted that a 200th Starbucks store, located in Cleveland Ohio, recently voted to unionize with Starbuck Workers United, so that trend is continuing.