BILL ANALYSIS                                                                                                                                                                                                    Ó

                               REVISED (3/21/11)


                     SENATE GOVERNANCE & FINANCE COMMITTEE
                            Senator Lois Wolk, Chair
          

          BILL NO:  SB 156                      HEARING:  3/23/11
          AUTHOR:  Emmerson                     FISCAL:  Yes
          VERSION:  3/15/11                     TAX LEVY:  Yes
          CONSULTANT:  Miller                   

                                  JOBS CREDIT
          

          Expands the Jobs Tax Credit to taxpayers that employ 50 or 
          fewer employees


                           Background and Existing Law
                                         
          The February, 2009 Budget Agreement included a Jobs Tax 
          credit beginning in the taxable year 2009 of $3,000 per 
          full time employee hired for an employer that employs fewer 
          than 20 employees (AB 3x 15, Chapter 10, Statutes of 2009 & 
          SB 3x 15, Chapter 17, statutes of 2009).  The credit is 
          capped at $400 million for all taxable years and allocated 
          by the Franchise Tax Board (FTB).  The credit remains in 
          effect until the total amount is exhausted.   The bill 
          requires the FTB to disallow credits claimed on returns 
          filed after the end of the calendar quarter in which the 
          FTB believes the cap will be reached.  Any credits not used 
          in the taxable year may be carried forward up to eight 
          taxable years.

          Current law also contains anti-abuse laws that prevent a 
          company from qualifying as "first commencing business in 
          the state" if the company only changes structures.  For 
          example, if Gracie Mae Kids Clothes changes from a sole 
          proprietorship to an S-Corporation, it would not be 
          considered a new business.  

                                   Proposed Law
                                         
          This bill changes the current requirement that taxpayers 
          have 20 or fewer employees to qualify for the credit to 50 
          or fewer employees.  

          This bill also repeals the anti-abuse laws described above. 






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                               State Revenue Impact
           This bill expands an existing capped and allocated credit 
          but does not expand it, so there is no revenue impact or 
          state cost associated with it.





                                     Comments
                                         
          1.   Purpose of the bill  .  In 2009, $400 million was set 
          aside in the budget to allow small businesses with 20 or 
          fewer employees to earn a $3,000 tax credit for every new 
          employee hired.  To date, less than $40 million has been 
          utilized for this program, leaving over $360 million still 
          available.  SB 156 would not increase the funding available 
          in the existing tax credit but would simply expand the 
          number of businesses that would be eligible for this tax 
          credit to those that have 50 or fewer employees.  This 
          expansion is intended to help spur job creation and 
          expedite California's economic recovery. 

          2.   Too Late?   The bill enacting the credit requires the 
          FTB to disallow credits claimed on returns filed after the 
          end of the calendar quarter in which the FTB believes the 
          cap will be reached.  The FTB currently projects that the 
          existing Jobs Tax credit will be exhausted during the 2011 
          taxable year based on historic trends of credit usage.  If 
          so, there will be no available credits on January 1, 2012 
          when this bill takes effect which may make this bill 
          unnecessary.  

          3.   What a way to make a living.   This credit has been in 
          effect since 2009 and there is little evidence that it has 
          affected unemployment in this state.  California 
          experienced steep employment declines during the recent 
          recession and the state's unemployment rate is persistently 
          higher than the national average.  Academic literature 
          suggests that no state tax policy can affect high 
          unemployment in this state.  A recent study by David 
          Neumark at the Public Policy Institute of California (PPIC) 
          suggests two direct job creation policies: hiring credits 
          and worker subsidies such as the federal Earned Income Tax 
          Credit.  At the February 16th hearing of this committee, 
          Mr. Neumark presented his findings.  He argues that hiring 
          credits act to increase the demand for labor and are the 





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          best policy response to spur a recovery from the recession. 
           He suggests that hiring credits should focus broadly on 
          the recently unemployed and establish incentives for new 
          hires rather than increases in the work hours of existing 
          employees.  In order to be effective, the credits would 
          need to be between $9,100 to $75,000 per employee so state 
          funding would contribute only modestly at best to the 
          credit.  

          4.   Enterprise Zones:   Most other states' hiring credits 
          look more like California's enterprise zones than a 
          stand-alone per employee credit.   Florida, New York, and 
          Illinois all offer credits within these zones.  Proponents 
          of the Enterprise Zone program state that it is the state's 
          best tool for economic development and decreasing 
          unemployment, citing accounts from taxpayers who say that 
          they locate in California largely because of enterprise 
          zone program incentives, which overcome disadvantages posed 
          by California's tax and regulatory system.  Supporters 
          argue that the tax credits draw investment into 
          economically distressed communities and provide incentives 
          for firms to employ hard-to-hire individuals.  However, 
          detractors state that the program offers a poor return on 
          the state's investment, especially the Targeted Employment 
          Area (TEA) criterion, and the practice of 
          "retro-vouchering."
          5.   Pro-abuse?   This bill repeals the existing anti-abuse 
          laws that do not allow companies a new business advantage 
          when changing corporate structures from a sole 
          proprietorship to an LLC for example.  

          The committee may wish to reinstate these rules as they 
          ensure that taxpayers do not "double dip" on any business 
          incentives.  If the committee wishes to amend the bill, the 
          language on page 7, lines 28-31 of the bill, would be 
          reinstated. 

          6.   Technical Amendment:   The author has agreed to take a 
          technical amendment on page 13, line 36, to strike out (f) 
          of section 17276 and insert "(g) of section 24416."

                         Support and Opposition  (3/21/11)

           Support  :  None received.

           Opposition  :  American Federation of State, County and 
          Municipal Employees (AFSCME), California Tax Reform 





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          Association.