BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 1956
                                                                  Page  1

          Date of Hearing:  May 13, 2014


                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Raul Bocanegra, Chair

                    AB 1956 (Bonilla) - As Amended:  April 1, 2014
           

                                       SUSPENSE
           

           Tax levy.  Majority vote.  Fiscal committee.
           
          SUBJECT  :  Personal income tax:  credit:  qualified tuition  
          program

           SUMMARY  :  Provides a credit in the amount of 20% of the  
          contributions made to a qualified tuition program, not to exceed  
          $500 per return.  Specifically,  this bill  :  

          1)Provides, beginning on or after January 1, 2015, a refundable  
            credit, as specified, against the "net tax" to a qualified  
            taxpayer who contributes money to a qualified tuition program.

          2)Provides that the amount of the credit shall be the lesser of  
            the following:

             a)   20% of the monetary contributions made by a qualified  
               taxpayer to a qualified tuition program that the qualified  
               taxpayer owns during a taxable year; or,

             b)   $500.

          3)Provides that the portion of the credit that is in excess of  
            tax liability shall, upon an appropriation by the Legislature,  
            be paid to the qualified taxpayer.

          4)Defines a "qualified tuition program" in the same manner as a  
            qualified tuition program under Internal Revenue Code (IRC)  
            Section 529.

          5)Defines a "qualified taxpayer" as an individual who, on behalf  
            of a beneficiary, contributes money to a qualified tuition  
            program for which the individual is the account owner and has  








                                                                  AB 1956
                                                                  Page  2

            an adjusted gross income of either:

             a)   $100,000 or less if the qualified taxpayer files as  
               single, married filing separately, or domestic registered  
               partner filing separately; or,

             b)   $200,000 or less if the qualified taxpayer files as head  
               of household, surviving spouse, married filing jointly, or  
               domestic partner filing jointly.

          6)Allows, in the case of married taxpayers or domestic partners  
            who file separate returns, the credit to be taken by either  
            spouse or registered domestic partner, or divided equally  
            between the spouses or registered domestic partners.

          7)Defines a "nonqualified withdrawal" as any payment or  
            distribution from a qualified tuition program that is subject  
            to an additional tax as provided for by IRC Section 529.   

          8)Provides that when a qualified taxpayer receives a  
            nonqualified withdrawal, in addition to any other tax, an  
            additional tax shall be imposed in an amount that is the  
            lesser of 10% of the nonqualified withdrawal or the total  
            amount of credits received for the taxable year and for all  
            prior taxable years that a qualified taxpayer was allowed a  
            credit pursuant to this bill.

          9)Provides that the Franchise Tax Board may proscribe rules,  
            guidelines, or procedures necessary or appropriate to carry  
            out the purposes of this section.

          10)Takes effect immediately as a tax levy.

           EXISTING FEDERAL LAW  provides tax-exempt status to qualified  
          tuition programs.  Qualified tuition programs are programs  
          established and maintained by a state (or by an eligible  
          education institution) under which a person may purchase tuition  
          credit or make cash contributions to meet the qualified higher  
          education expenses of a designated beneficiary.  Contributions  
          to a qualified tuition program cannot exceed the amount  
          necessary to provide for the beneficiary's qualified higher  
          education expenses.  Distributions to a beneficiary are excluded  
          from income.  However, contributions made to a qualified tuition  
          program are not deductible.









                                                                  AB 1956
                                                                  Page  3

           EXISTING STATE LAW  :

          1)Conforms to IRC Section 529 as of the "specified date" of  
            January 1, 2009, with certain state modifications, including a  
            modification to the 10% tax on excess distributions to instead  
            be an additional tax of 2.5% for state purposes.

          2)Provides its own IRC Section 529 qualified tuition program,  
            known as the Golden State Scholarshare Trust (ScholarShare).   
            ScholarShare enables taxpayers to save for college by putting  
            money in tax-advantaged investments.  After-tax contributions  
            allow earnings to grow tax-deferred, and disbursements, when  
            used for tuition and other qualified expenses, are federal and  
            state tax-free.  Distributions in excess of qualified higher  
            education expenses incurred for the beneficiary, the portion  
            of the excess that is treated as earnings generally is subject  
            to income tax and an additional 2.5% tax for state purposes.  

          3)Limits the total amount of contributions to a beneficiary to  
            $371,000.  Accounts that have reached the limit may continue  
            to accrue earnings.  

           FISCAL EFFECT  :  Unknown

           COMMENTS  :   

          1)The author states, "[c]hildren with college savings accounts  
            are seven-times more likely to attend college.  AB 1956 will  
            increase the number of families saving for college and also  
            increase the amount of money they set aside for higher  
            education.  California is one of only seven states with  
            personal income taxes that does not offer any type of tax  
            incentives for saving with a 529 plan.  Californians have  
            nearly $100 billion in student debt.  It is estimated that  
            this bill will decrease student debt by more than $700 million  
            within 20 years.  AB 1956 will stimulate economic activity by  
            providing college graduates with more disposable income to  
            make major purchases such as buying a home or automobile."

          2)Proponents state, "[s]tudent debt continues to rise, with 52%  
            of graduates incurring an average debt of nearly $26,000.   
            This mounting student debt places a damper on the state's  
            economic activity because current debt holders have less  
            disposable income to purchase a home, car, and other  
            beneficial economic improvements.  Starting early saving with  








                                                                  AB 1956
                                                                  Page  4

            a 529 account and saving regularly can significantly help ease  
            college debt burdens."  Proponents also state, "[i]t is  
            projected that the bill's provisions will decrease student  
            debt in California by more than $600 million over 20 years.   
            Lower debt payments will enable college graduate to use their  
            increased disposable income for major purchases that increase  
            tax revenues, such as buying a home."

          3)Opponents of this bill state that "[r]efundable tax credits  
            also create great opportunities for fraud.  An August 2013  
            report by the U.S. Treasury's inspector general for tax  
            administration estimated that 21 percent to 25 percent of  
            federal earned income tax credit payments were improperly  
            issued during 2012, amounting to approximately $11 billion in  
            improper payments.  Also, California's two popular, formerly  
            refundable credits - the renters' credit and the child and  
            dependent care expenses credit - had very high fraud rates,  
            prompting the Legislature to repeal their refundability." 

          4)Committee Staff Comments:

              a)   Conformity issues  .  As noted above, California conforms  
               to IRC Section 529, with slight modifications.  In general,  
               state conformity with federal law promotes greater  
               simplicity and eases administration of complex tax laws.   
               The Federal Government does not provide a credit for  
               contributions to a 529 plan.  By providing a refundable  
               credit for contributions made to qualified tuitions  
               programs, this bill would bring California out of  
               conformity with federal law.

              b)   Favoring Higher Income Earners  .  According to a report  
               by the Government Accountability Office (GAO), less than 3%  
               of families have 529 or Coverdell plans and those who do  
               tend to be wealthier.  (Higher Education: A Small  
               Percentage of Families Save in 529 Plans, GAO, Dec. 2012.)   
               Specifically, families with 529 and Coverdell plans had a  
               median income of $142,000 per year and a median financial  
               asset value of about $413,500.  It was also said that  
               families with 529 plans tend to have higher levels of  
               education, which may increase the likelihood that their  
               children will attend college.    

               The report outlined several reasons why low-income families  
               participate far less in 529 plans, such as a lack of  








                                                                  AB 1956
                                                                  Page  5

               awareness, confusion as to how the plan works, and  
               differences among the various 529 plans.  However, 68% of  
               those surveyed stated a lack of money as the major reason  
               for not participating.  In the end, it is difficult to  
               encourage families to save for college when they have  
               little or no disposable income.   

              c)   Low-Income Earners May Never See a Credit  .  This bill  
               provides that the portion of the credit that is in excess  
               of tax liability shall, upon an appropriation by the  
               Legislature, be paid to the qualified taxpayer.  By  
               providing a refundable credit for contributions made to a  
               qualified tuition program, this provision may encourage  
               low-income families to save for college.  However, this  
               bill, as currently written, requires a subsequent  
               appropriation of funds by the Legislature, which means  
               certain taxpayers may not receive a credit despite making  
               contributions.  Additionally, the bill is unclear as to  
               whether the appropriated funds would apply to a single  
               taxable year or to multiple years.  The fact that the  
               refundability of the credit is not certain means that  
               low-income families are less likely to participate.

              d)   High Cost of a Formal Education  .  State support for  
               higher education has been dramatically reduced because of  
               budget crises over the last 10 years.  According to a study  
               by the Public Policy Institute of California, in 2010-11,  
               California spent $1.6 billion less in higher education than  
               it did 10 years earlier, adjusted for inflation.  (Hans  
               Johnson, Defunding Higher Education:  What are the Effects  
               on College Enrollment, Public Policy Institute of  
               California, May 2012.)  The provisions of this bill are  
               meant to counteract the skyrocketing costs of an education  
               by providing a credit for contributions made to qualified  
               tuition programs.  Instead of forgoing general fund  
               revenues that predominantly favor higher income earners,  
               these funds may be better utilized if directly appropriated  
               to the state's University of California, California State  
               University, and Community College system.

              e)   Related Legislation  .  AB 1796 (Linder) would allow a  
               deduction for contributions made to a qualified tuition  
               program.  AB 1796 is pending hearing by this Committee.

              f)   Prior Legislation  .  AB 675 (Gilmore), of the 2009-10  








                                                                  AB 1956
                                                                  Page  6

               Legislation Session, would have allowed a deduction for  
               contributions made to a qualified tuition program.  AB 675  
               was held in this Committee.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Bill Lockyer, California State Treasurer (Sponsor)
          Asset Building Strategies 
          California Association of Private School Organizations
          California Catholic Conference
          Financial Services Institute
          National Association of Insurance Advisors-California
          State Farm Mutual Automobile Insurance Company

           Opposition 
           
          The American Federation of State, County and Municipal Employees
          California Tax Reform Association
          California Taxpayers Association
          California Teachers Association
           
          Analysis Prepared by  :  Carlos Anguiano / REV. & TAX. / (916)  
          319-2098