BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 71
                                                                  Page  1

          Date of Hearing:  January 14, 2008

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                               Charles Calderon, Chair

                     AB 71 (Dymally) - As Amended:  June 12, 2007


                                      VOTE ONLY

           
           Majority vote.  Tax levy.  Fiscal committee.
           
          SUBJECT  :  Personal income and corporation taxes:  credits:   
          employee health insurance

          SUMMARY  :  Provides a tax credit to small employers that provide  
          health insurance for low and moderate wage employees.   
          Specifically,  this bill  :  

          1)Allows a tax credit to a qualified small employer equal to 25%  
            of the amount paid during the taxable year for qualified  
            health insurance expenses for qualified employees. 

          2)Applies to each taxable year beginning on or after January 1,  
            201_ and before January 1, 201_.

          3)Provides definitions for the following terms:

             a)   "Qualified small employer" means any small employer that  
               does both of the following:

               i)     Offers health insurance coverage to all qualified  
                 employees, following any applicable waiting period set  
                 forth in federal law.

               ii)    Pays at least 50% of the cost of health insurance  
                 coverage for each qualified employee.

             b)   "Small employer" means an employer of more than 1 but  
               less than 11 full-time employees on average during the  
               taxable year.  

             c)   "Qualified employee" means an employee of a qualified  
               small employer who performs more than 50% of his or her  








                                                                  AB 71
                                                                  Page  2

               services within California in any calendar year and who is  
               reasonably expected to receive compensation of not more  
               than $50,000 during the calendar year.  Specifically:

               i)     Excludes an employee that is provided health  
                 insurance coverage under a spouse's health plan, any  
                 other individual or group health plan, any federal  
                 provision, or any other law.

               ii)    Excludes self-employed persons treated as employees.

               iii)   Includes leased employees.

             d)   "Compensation" is defined by reference to Internal  
               Revenue Code (IRC) Section 3401(a).

             e)   "Qualified health insurance expenses" means any amount  
               paid or incurred by a qualified small employer for health  
               insurance coverage during the taxable year.  Specifically: 
             
               i)     Limits the amount to $5,000 for each qualified  
                 employee during the taxpayer year to the extent that it  
                 is for coverage provided to any employee and the  
                 employee's spouse.

               ii)    Excludes the incremental amounts paid for health  
                 insurance coverage for a qualified employee's dependents  
                 if the employer offers coverage for them.  

               iii)   Excludes any amount paid or incurred for health  
                 insurance coverage under a salary reduction arrangement.

             f)   "Health insurance coverage" is defined by reference to  
               IRC Section 9832(b)(1).

          4)Provides for an annual adjustment to the maximum compensation  
            amount equal to that set out in the Medi-Cal/Healthy Families  
            Program. 

          5)Denies any other deduction or credit for any costs paid or  
            incurred for the taxable year for which this credit is  
            allowed.

          6)Allows carryover of any unused credit for the next succeeding  
            seven years.








                                                                  AB 71
                                                                  Page  3


          7)Permits the Franchise Tax Board (FTB) to prescribe regulations  
            as may be necessary or appropriate to carry out the purposes  
            of this bill.

          8)Remains in effect until December 31, 201_ and is repealed as  
            of that date.

          9)Takes effect immediately as a tax levy.

           EXISTING LAW  allows various tax credits designed to provide  
          relief to taxpayers incurring specified expenses or to influence  
          behavior that might not occur without the tax incentive. 

           FISCAL EFFECT  :  Assuming this bill goes into immediate effect,  
          FTB estimates revenue losses of $165 million in fiscal year (FY)  
          2008-09, and $225 million in FY 2009-10

           Proposition 98 Fiscal Effect  :  Committee staff estimate a loss  
          in funding for K-14 schools of $-0- in FY 2008-09, and $30  
          million in FY 2009-10.

           COMMENTS  :   

          1)Assemblymember Dymally wants to create an incentive that will  
            encourage more employers in the lowest percent of those  
            providing health care coverage - the small employers.  In  
            order to keep the cost of health insurance coverage as low as  
            possible, this credit will be available only for health  
            insurance coverage for employees and their spouses.  The  
            author intends that children of the qualified employees will  
            continue to be covered by the Medi-Cal Healthy Families  
            Program.  

          2)The author intends this bill to provide a tax incentive to  
            small employers who are not covered by other mandates or  
            incentives, including any mandatory health care laws enacted  
            during this legislative session.  The specific elements of  
            this bill, such as number of employees and amount of the  
            credit, would be coordinated with any other plan or plans  
            adopted by the Legislature. 

          3)According to the California Health Care Foundation, only 62%  
            of employers with three to nine employees offer health care  
            coverage.  The same report shows that over 94% of employers  








                                                                  AB 71
                                                                  Page  4

            with 50 employees or more offer health care coverage.  High  
            premiums for insurance (primarily related to minimal ability  
            to spread risks) was cited by more than 68% of the survey  
            respondents as the primary reason that small employers do not  
            provide health insurance.

          4)Proponents state that certain groups of individuals are less  
            likely to have employer-provided health insurance and that the  
            number of firms that offer health benefits has declined since  
            2000.  The decline in coverage is more prevalent in small  
            businesses.  The ability of small businesses to offer adequate  
            health coverage is important to their success over the long  
            run as well as the general well-being of the California  
            economy.

          5)Opponents state that this bill will provide a credit to many  
            employers that already provide health insurance to their  
            employees.  Opponents state that this bill creates  
            inefficiency by giving substantial credits to employers that  
            already provide health insurance coverage.  Opponents state  
            that, given the need to cover the uninsured and the limited  
            dollars available, much of the funds spent under this bill  
            will provide no benefit of increased coverage.
           
          6)Committee staff note that there are numerous proposals that  
            would require employers to provide health insurance for their  
            employees, or to pay into a state-controlled fund that will  
            acquire the health coverage for them.  However, most proposals  
            contain an exception for small employers, determined as those  
            with less than a stated number of employees.  The maximum  
            number of employees allowed for the definition of small  
            employer varies with the different proposals, but range from 2  
            to 10 employees.  Committee staff understand that this bill is  
            intended to create an incentive for those employers exempted  
            from mandatory coverage requirements, thereby requiring  
            coordination with the measure ultimately adopted, is any, for  
            consistency of application.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Association of Nonprofits
          California Black Chamber of Commerce
          California State Employees Association








                                                                  AB 71
                                                                  Page  5

          National Federation of Independent Business
          California Hispanic Chamber of Commerce
          FCI Management Consultants
          California Restaurant Association

           Opposition 
           
          California Tax Reform Association 
           
          Analysis Prepared by  :  M. David Ruff / Kimberly Bott / REV. &  
          TAX. / (916) 319-2098