This is the new part....
I had a meeting with my accountant in early August in which I specifically brought up the subject of use tax, as it's been clear to me that California governments are so hurting for funds that they're going to go after every opportunity to nail you. At the time of the meeting, she told me that unless I was selling merchandise, I had no requirements to file any forms with the BOE... and therefore would encounter no use tax reporting form.
If the reporting requirements have changed, this is a matter of concern. One simply does not want to cross the California State Board of Equalization. I have seen them effectively put companies out of business by retroactive audits that tied them up forever. BOE reporting forms (of sales tax collected), eg, require county by county itemization, among the most byzantine forms I've ever seen. (I for one would welcome more centralization in this case).
Among their penalties I've seen in the past... possibly not applicable here, but there is a parallel... if you had a resellers permit and used that to avoid paying sales tax on certain items, they would change your status from a non-taxable service company to a company on which all transactions were taxable. I don't know what they'd do regarding use tax, but I'd really rather not fool with them.
The question here is what is the threshold for filing the new form? I can't find anything specific on their website.