BILL ANALYSIS Ó
AB 2421
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Date of Hearing: May 13, 2014
ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
Raul Bocanegra, Chair
AB 2421 (Nestande) - As Amended: April 22, 2014
Majority vote. Fiscal committee. Tax levy.
SUBJECT : Corporation Tax Law: credits: Homeless and Foster
Youth Opportunities Investment Act
SUMMARY : Enacts the Homeless and Foster Youth Opportunities
Investment Act. Specifically, this bill :
1)Contains the following legislative findings and declarations:
a) Providing tax incentives to encourage private
investments for the common good is sound public policy.
b) Expanding educational opportunities and improving the
quality of, and access to, educational services within the
state are valid public purposes that the legislature may
promote using its sovereign power to determine tax policy.
c) Creative tax policy can inspire greater charitable
contributions and public-private partnership that ensure
additional resources for the education of all children in
California.
d) Encouraging voluntary support for education, without
prejudice for or against any state-sanctioned educational
enterprise promotes the state's interest and common good in
providing the highest quality education to all children in
the state.
e) At a time when fiscal realities challenging California
school communities demand innovative ways to deliver vital
education services to public private pupils in kindergarten
and grades 1 through 12, and in college, charitable giving
for educational purposes should be stimulated.
f) California benefits from ensuring accessibility and
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viability of strong public, as well as, private school
options in educating students, especially for those with
the greatest needs: our homeless and foster youth.
2)Allows, for taxable years beginning on or after January 1,
2015, and before January 1, 2020, a credit under the
Corporation Tax (CT) Law equal to 50% of a taxpayer's monetary
contributions made during the taxable year, not to exceed
$200,000, to a "qualified education scholarship organization"
to fund qualified college or K-12 education scholarships for a
specified pupil to attend private school or to fund partial or
full payments of fees associated with the general costs of
transportation to attend a private, public, or charter school.
3)Defines "qualified education scholarship organization" or
"ESO" to mean an organization that meets the following
requirements:
a) Is organized and operated with the purpose of providing
qualified college or K-12 education scholarships to pupils
attending a public or private school in California.
Organizations with three or more years of audited financial
statements must distribute at least 80 percent of
contributions for which a credit is claimed, and
Organizations with fewer than three years of audited
financial statements must distribute 90 percent of
contributions for which a credit is claimed;
b) Makes qualified college or K-12 education scholarships
available for specified pupils from more than one school.
c) Retains data on the progress of the specified pupils
participating in qualified college or K-12 education
scholarships on nationally available norm-referenced tests
to evaluate the programs efficacy.
d) Submits financial and compliance audit reports performed
by a certified public accountant to the Franchise Tax Board
(FTB).
e) Submits quarterly reports on the number of qualified
college or K-12 education scholarship recipients and the
schools that the recipients attend to the State Department
of Education.
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f) Applies to participate in this credit program with the
State Department of Education.
g) Is formed as any of the following:
i) A nonprofit public benefit corporation described in
Corporations Code (CC) Section 5110 et seq.;
ii) A nonprofit religious corporation described in CC
Section 9110 et seq.;
iii) A duly authorized foreign nonprofit corporation that
has complied with all registration requirements in the
CC, as specified; or,
iv) Is an organization exempt from federal income tax as
an organization described in Internal Revenue Code (IRC)
Section 501(c)(3).
4)Defines "qualified college or K-12 education scholarship" to
mean any of the following:
a) An award of tuition assistance amounting to a least 65%
of the basic state per-pupil funding, or a private school's
actual tuition and fees, whichever is less. The award must
meet the following requirements:
i) An initial college or K-12 education scholarship
shall be awarded to a specified pupil in kindergarten
through grade 12 or in college;
ii) May be renewed at the request of the specified pupil
for each school year until graduation from high school or
college;
iii) Shall be portable and follow the specified pupil
from one school to another; and,
iv) Shall be provided to a private school of the
specified pupil's choosing under the following
conditions:
(1) Each ESO shall establish criteria for granting
scholarships that meet the requirements of this
section;
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(2) The pupil receiving the assistance shall
remain a specified pupil;
(3) The specified pupil shall attend a private
school;
(4) The specified pupil shall remain enrolled and
in attendance at the private school throughout the
school year unless excused by the applicable program
for illness or other good cause;
(5) The specified pupil and the parent or legal
guardian shall comply with all applicable policies of
the private school; and,
(6) A parent or legal guardian of the specified
pupil shall ensure that the pupil has reliable
transportation to and from the applicable program.
b) Financial assistance for a specified pupil to partially
or fully pay for the fees associated with the general costs
of transportation to attend a private, public, or charter
school or to attend school-related activities and other
educationally beneficial programs;
c) Financial assistance for a specified pupil to attend
college courses after graduation from high school provided
by any public or independent college where the specified
pupil has been admitted to attend; and,
d) Financial assistance for a specified pupil to purchase
books and other materials to support academic success,
including, but not limited to, computers and software,
tutoring, and other academic support.
5)Defines "specified pupil" to mean an individual who has
applied for a college of K-12 education scholarship and who is
either within foster care or has been placed in a foster care
system within the State of California at any time prior to
graduating high school, or who was at any time prior to
graduating high school, or is currently a homeless youth as
defined by Government Code Section 11139.3. A specified pupil
is not required to be previously enrolled in a public school
or charter school to participate.
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6)Defines "private school" to mean a person, firm, association,
partnership, limited liability company, or corporation
offering or conducting private school instruction in the State
of California on the elementary or high school level, that
meets all of the following:
a) Is accredited by the Western Association of Schools and
Colleges or an affiliated organization;
b) Has filed a current private school affidavit with the
State Department of Education in accordance with Section
33190 of the Education Code;
c) Complies with applicable provisions of the Health and
Safety Code;
d) Complies with applicable provisions of the California
Fair Employment and Housing Act (Part 2.8 (commencing with
Section 12900) of Division 3 of Title 2 of the Government
Code);
e) Utilizes background checks in connection with hiring all
school employees, consistent with the standards set forth
in Education Code Section 44237(a);
f) Requires a specified pupil to take nationally available
norm-referenced test; and,
g) Has obtained, if it has been in operation for less than
three years, a surety bond or letter of credit in an amount
equal to the value of the education scholarship payment for
one quarter.
7)Provides that "private school" also means an institution that
meets the definition of a "qualifying institution" in
Education Code Section 69432.7. A "private school" does not
include program of instruction offered by a tutor or a
non-accredited private school to a pupil who is exempt from
compulsory full-time education as provided for in Education
Code (commencing with Section 48220).
8)Provides that the taxpayer shall receive a certification by
the State Department of Education upon a determination that
the contribution meets the necessary requirements.
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9)Provides that the scholarship tax credit shall be in lieu of
any other credit or deduction that the taxpayer may otherwise
claim pursuant to the CT law for the same monetary
contribution, as specified, and requires the credit to be
claimed on a timely filed original return.
10)Limits the aggregate amount of the tax credits allowed to $50
million for each calendar year but authorizes the Legislature
to increase the amount.
11)Provides that the FTB and the State Department of Education
shall administer the credit, and that the allocation of
credits be made on a first-come, first-serve basis.
12)Provides that the FTB is required to do all of the following:
a) Adopt rules and regulations as necessary or appropriate
to implement this credit;
b) Track credits claimed;
c) Post aggregate totals of the credits claimed on the
Internet Web site of the FTB; and,
d) Determine when the aggregate total of the credits
reaches $50 million for a calendar year.
13)Provides that the State Department of Education is required
to do all of the following:
a) Adopt rules and regulations necessary to determine
whether an ESO and a contribution meet specified
requirements;
b) Submit a list of eligible ESOs that comply with
specified requirements to the FTB annually by March 15;
c) Establish application forms and procedures; and,
d) Certify that the contributions meet specified
requirements.
14)Provides that this bill shall remain in effect only until
December 1, 2020, and as of that date is repealed.
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15)Takes effect immediately as a tax levy.
EXISTING LAW :
1)Provides various tax credits designed to provide tax relief to
taxpayers who incur certain expenses (e.g., child adoption) or
to influence behavior, i.e. to provide incentives for
taxpayers to perform various activities that they may not
otherwise undertake.
2)Allows individual and corporate taxpayers to deduct certain
expenses as itemized deductions.
3)Allows deductions for monetary charitable contributions,
gifts, or property to qualified organizations formed for
religious, charitable, educational, scientific, or literary
purposes. A charitable contribution is defined as a
contribution or gift made exclusively for public purposes.
Individual taxpayers can claim charitable contributions as an
itemized deduction and can deduct the greater of the standard
deduction or itemized deductions from their adjusted gross
income (AGI) when computing taxable income. Corporate
taxpayers can claim charitable contributions up to 10% of the
corporation's taxable income, without regard to the amount of
charitable contribution, but the amount in excess of the 10%
limitation may be carried over for five years.
4)Imposes limitations on the amount of deduction for individual
charitable contributions, depending on the individual's AGI
and the amount of contributions, the types of organizations
that receive the donations, and the type of property donated.
FISCAL EFFECT : The FTB estimates that this bill will reduce
general fund revenue by $9 million in fiscal year (FY) 2014-15,
$30 million in 2015-16, and $50 million in 2016-17
COMMENTS :
1)Author's Statement . The author has provided the following
statement in support of this bill:
The use of tax policy to influence behavior is an important
tool for government. AB 2421 presents a unique opportunity
to incentivize corporate donations to provide key resources
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for foster and homeless youth. These vulnerable
populations face daunting challenges when striving to
receive a quality education and require support to achieve
their goals. Working through non-profits, AB 2421 would
provide college scholarships to help bridge the gap between
the cost of attending school and currently available
financial aid. It would also provide scholarships to cover
transportation costs so these students could be provided
the stability of remaining in their current K-12 school
when moving from home-to-home. Lastly, if a student is
struggling in the classroom and would benefit from a
smaller school environment, scholarships would be available
to allow them to attend a K-12 school of their choice.
Foster and homeless youth tend to have drastically lower
college completion rates than traditional students. It's
time for California to help change this.
2)Arguments in Support . Supporters of this measure state that
"creating tax incentives to encourage private investments for
the common good is sound public policy. This bill would
inspire greater philanthropic contributions, and
public-private partnerships, to ensure new resources that
deliver vital education services to highly at-risk public and
private school students from kindergarten into college. Such
charitable contributions would ensure accessibility and
viability of learning environments that best support students
in homeless situations to get to, stay in, and be successful
in school." Furthermore, supporters believe that
"California's children have an inalienable right to a quality
education. This principle extends from a students' elementary
education, through high school, and into opportunities for
postsecondary learning."
3)Arguments in Opposition . Opponents believe that public
education should be financed directly from public funds
instead of educational funding systems like vouchers,
scholarships, or tuition tax credits. Furthermore, opponents
are against "any reduction in revenue to the State's General
Fund which would reduce Proposition 98 funding. In the last
several years, K-12 education alone has taken over $20 billion
in cuts. This does not include cuts that have hit the
California Community Colleges, [California State University]
and [University of California] systems. Likewise, we must not
forget the cuts that have also hit our social and health
services, safety programs, and many other essential services."
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Additionally, opponents along with a number of organizations
"worked hard in the fall of 2012 to add revenues to the
General Fund via the tax initiative, Proposition 30. Why
would the Legislature consider a measure that will take away
from the General Fund, when so many people worked so hard to
increase those General Fund revenues?" Finally, opponents
argue that "[b]ecause private religious schools are not 'under
the exclusive control of the officers of the public schools'
and furthermore provide religious teachings during the school
day, providing tax credits for funding these schools violates
provisions of the California Constitution. Article IX,
Section 8 of the state Constitution provides: 'No public
money shall ever be appropriated for the support of any
sectarian or denominational school, or any school not under
the exclusive control of the officers of public schools?' In
addition, Article XVI, Section 5 prohibits the use of tax
funds 'to support or sustain any school? controlled by any
religious creed, church, or sectarian denomination
whatever?.'"
4)What does this bill do ? As pointed out by the author, public
and private schools have been struggling to provide high
quality education to children in California. This bill would
provide a tax incentive for contributions to pay for tuition
of foster youth students in a K-12 or college program.
Specifically, this bill would allow a corporation to claim a
tax credit for monetary contributions to a nonprofit
organization that gives scholarships for foster youth to
attend public or private K-12 schools or universities.
The amount of credit is limited to 50% of the amount of the
monetary contribution made during the taxable year, and may
not exceed $200,000. Unlike many other tax incentives, the
proposed tax credit is capped and allocated. The credit is
effective only for five taxable years, from 2015 until 2020;
and the annual aggregate amount of the credit may not exceed
$50 million (although this bill authorizes the Legislature to
increase this amount). The Department of Education and the
FTB are required to allocate and certify the credits on a
first-come, first-serve basis, up to $50 million for each
taxable year. The credit is not refundable and, in many
respects, is similar to a grant program.
1)Do Scholarship Tax Credit Programs Provide Educational
Benefits ? The proposed scholarship tax credit program is
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intended to encourage corporate contributions to fund
scholarships for foster youth to attend private schools. It
is presumed that the proposed tax incentive will not only
result in a significant increase in the amount of private
monetary support for the schools, but also will lead to some
substantial educational benefits to students in both public
and private schools. While it is challenging to quantify the
impact or effectiveness of a tax incentive, several studies
have attempted to do just that with respect to scholarship and
tuition tax credits.
One of these studies was conducted by the U.S. Department of
Education to determine the effectiveness of the District of
Columbia School Choice Incentive Act of 2003, passed by
Congress in January 2004. This Act established the first
federally funded, private school voucher program in the United
States - the DC Opportunity Scholarship Program (OSP).<1>
According to the U.S. Department of Education report, the
purpose of the new scholarship program was to provide
low-income residents, particularly those whose children attend
schools in need of improvement or corrective action under the
Elementary and Secondary Education Act, with expanded
opportunities to attend higher performing schools in the
District of Columbia. The scholarship, worth up to $7,500,
could be used to cover the costs of tuition, school fees, and
transportation to a participating private school. It should
be noted that, as part of this legislation, Congress mandated
a rigorous evaluation of the impacts of the program.
The evaluation study found that there "was no conclusive
evidence that the OSP affected student achievement."<2>
Specifically, "after at least four years students who were
offered (or used) scholarships had reading and math test
scores that were statistically similar to those who were not
---------------------------
<1> Wolf, Patrick, Babette Gutmann, Michael Puma, Brian Kisida,
Lou Rizzo, Nada Eissa, and Matthew Carr. Evaluation of the DC
Opportunity Scholarship Program: Final Report (NCEE 2010-4018).
Washington, DC: National Center for Education Evaluation and
Regional Assistance, Institute of Education Sciences, U.S.
Department of Education.
<2> Ibid., Executive Summary.
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offered scholarships."<3> At the same time, it was determined
that the OSP significantly improved students' chances of
graduating from high school. Thus, students graduated at
higher rates even though they may not have raised their test
scores in reading and math as a result of the OSP.<4>
Finally, the report concluded that the OSP raised parents' -
but not students' - ratings of school safety and
satisfaction.<5>
Another study reviewed the effectiveness of the Milwaukee
Parental Choice Program (MPCP).<6> The MPCP, which began in
1990, provides government-funded vouchers for low-income
children to attend private schools in the City of Milwaukee.
The maximum voucher amount in 2010-11 was $6,442, and 20,996
children used a voucher to attend either secular or religious
private schools. The MPCP is the oldest and largest urban
school voucher program in the United States.<7> The study
found that, for the 2010-11 school year, the students in the
MPCP sample exhibited larger growth (from the base year of
2006) in reading achievement than the students in the matched
Milwaukee Public Schools (MPS) sample.<8> However, the
authors of the study note that these results should be
interpreted with some caution because they "represent
differences that were not present in earlier years" and a
--------------------------
--------------------------
<3> Ibid., "The same pattern of results holds for students who
applied from schools in need of improvement (SINI), the group
Congress designated as the highest priority for the Program.
Although some other subgroups of students appeared to have
higher levels of reading achievement if they were offered or
used a scholarship, those findings could be due to chance. They
should be interpreted with caution since the results were no
longer significant after applying a statistical test to account
for multiple comparisons of treatment and control group members
across the subgroups."
<4> Ibid., "The offer of an OSP scholarship raised students'
probability of completing high school by 12 percentage points
overall (figure ES-3)."
<5> Ibid., Parents were more satisfied and felt school was safer
if their child was offered or used an OSP scholarship. The
Program had no effect on students' reports on school conditions.
<6> Witte, Wolf, et al., MCPC Longitudinal Educational Growth
Study Third Year Report (April 2010).
<7> Ibid.
<8> Ibid., "This is the first year such an achievement growth
advantage has been observed for either group in our study. Some
analyses indicate that the students in the MPCP sample also
exhibit larger growth in math achievement, but the results are
not conclusive."
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"significant program change took place in the final year."<9>
The report suggests that "there is some evidence that the
larger achievement growth of the MPCP students ? is
attributable to the introduction of the accountability
policy."
Furthermore, there is some evidence to suggest that voucher
and tuition tax credit programs do not necessarily offer
special needs students greater support programs. For example,
the U.S. Department of Education report showed that students
participating in the OSP were actually less likely than
students not participating in the program to have access to
programs such as English language learners, special needs
programs, tutors, counselors, etc.<10> As pointed out by the
opponents of this bill, reduced access to such programs by
special needs students and foster youth "is especially
problematic, given that the intention of AB 943 is to benefit
special needs children and children in foster care
programs."<11> Students attending public schools are
protected under the Individuals with Disabilities Act and it
is unclear whether they would continue receiving those
protections and services once they accept a scholarship and
transfer to a private school.
2)Tax Credits vs Vouchers . In recent years, certain education
analysts have advocated for nonrefundable education tax
---------------------------
<9> Ibid., Beginning with the 2010-11 school year, the MPCP
schools were subjected to a test-based accountability policy for
the first time, i.e. they were required to administer a test to
all voucher students in Grades 3-8 and 10 and publicly report
the results by named schools. "Because the test-based
accountability policy was introduced after we carefully matched
our sample of MPCP students to MPS students, this study is no
longer solely evaluating the effectiveness of the MPCP. Rather,
it is evaluating the effectiveness of both MPCP and the
accountability policy that was introduced in 2010-11."
<10> Wolf, Patrick, Babette Gutmann, Michael Puma, Brian Kisida,
Lou Rizzo, Nada Eissa, and Matthew Carr. Evaluation of the DC
Opportunity Scholarship Program: Final Report (NCEE 2010-4018).
Washington, DC: National Center for Education Evaluation and
Regional Assistance, Institute of Education Sciences, U.S.
Department of Education, pp. 56, 57, 60.
<11> Americans United for Separation of Church and State, Letter
in Opposition to AB 943, signed by Carol Velarde, President,
Sacramento Chapter, January 8, 2014.
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credits as a means of promoting "educational freedom." Some
researchers view such tax credits as a more viable alternative
to school vouchers. In a report published by the Cato
Institute, Adam B. Schaeffer argues that "tax credits enjoy
practical, legal, and political advantages over school
vouchers." (The Public Education Tax Credit, Adam B.
Schaeffer, Cato Institute, Policy Analysis, No. 605, December
5, 2007, p. 1.) Specifically, Schaeffer maintains that "the
pursuit of highly regulated and targeted voucher programs
impedes the rise of a competitive education industry and
creates unnecessary political disadvantages for school choice
supporters." (Id. at 2.) Moreover, Schaeffer points out that
tax credits are "more popular with the public and politicians,
less likely to be challenged in court, and more likely to
survive most court challenges." (Id.) Finally, Schaeffer
argues that "tax credits are a viable option in many states
where effective voucher programs are likely to be struck down
on state constitutional grounds." (Id. at 3.)
3)Potential Constitutional Challenges . The California
Constitution specifically prohibits the state from helping "to
support or sustain any school, college, university, hospital,
or other institution controlled by any religious creed,
church, or sectarian denomination whatever." (California
Constitution, Article XVI, Section 5.) However, this section
has never been interpreted to prohibit a religious institution
from receiving indirect, remote, and incidental benefits from
a statute which has a secular primary purpose. (Woodland
Hills Homeowners v. Los Angeles Community College District,
(1990) 218 Cal. App. 3d. 79.) Clearly, the state would be
prohibited from directly allocating funds to privately owned
religious organizations, but the question is whether a
subsidy, in this case a tax credit to corporations making
donations to an ESO that then provides scholarships for
payments to religious schools, is an indirect subsidy with
incidental benefits or a direct subsidy through an indirect
appropriation. In deciding the constitutionality of this
bill, it is important to understand the bill's intent. It is
technically possible, under the provisions of this bill, for a
foster youth to use scholarship funds for the payment of
tuition costs of a private, non-religious school, but the
reality is that roughly 68% of all private schools have some
religious orientation. (U.S. Department of Education,
Characteristics of Private Schools in the United States:
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Results From the 2007-08 Private School Universe Survey, March
2009) Therefore, even if not directly stated, this bill
appears to provide a substantial benefit that
disproportionately favors religious organizations. By
establishing an indirect subsidy program for private schools,
this bill may be challenged under this provision for
inappropriately using public funds to support private,
sectarian institutions.
4)The Not-so-Dormant Commerce Clause : The credits this bill
proposes apply only in connection with California-based
schools. By limiting the credits to in-state activity, this
bill could arguably be susceptible to challenge under the
dormant commerce clause of the U.S. Constitution.
The U.S. Constitution authorizes Congress to regulate commerce
with foreign nations, and among the several states. (U.S.
Constitution, Article I, Section 8, Clause 3.) While the
commerce clause is phrased as a positive grant of regulatory
power, it "has long been seen as a limitation on state
regulatory powers, as well as an affirmative grant of
congressional authority." [Fulton Corp. v. Faulkner (1996)
516 U.S. 325, 330.] This negative aspect, commonly referred
to as the dormant commerce clause, prohibits economic
protectionism in the form of state regulation that benefits
"instate economic interests by burdening out-of-state
competitors." (Ibid.)
Both the U.S. Supreme Court and the California courts have
addressed challenges to various state tax provisions on
dormant commerce clause grounds. Most recently, the Court of
Appeal struck down a California statute that allowed taxpayers
a deferral for income received from the sale of stock in
corporations maintaining assets and payroll in California,
while providing no such deferral for income from the sale of
stock in corporations maintaining assets and payroll
elsewhere. [Cutler v. Franchise Tax Board (2012) 208
Cal.App.4th 1247, 1250.] Specifically, the court held that
"the deferral provision discriminates on its face on the basis
of an interstate element in violation of the commerce clause."
(Ibid.)
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Thus, while no court decision has yet invalidated, as a
general matter, a state income tax credit that provides an
incentive for in-state activity, such credits may be subject
to constitutional challenge. Any potential constitutional
infirmity could be remedied by expanding this bill's
definition of public, private, and charter schools to include
schools located outside of California. While such a proposal
would be geographically neutral, it is hard to argue that
California should subsidize contributions that end up
benefiting schools located in other states.
5)Related Legislation :
a) AB 2422 (Nestande) would enact similar legislation by
creating the STEAM Investment and Incentive Act. AB 2422
will be heard by this Committee today.
b) AB 943 (Nestande) would have enacted similar legislation
by creating the Education Investment Incentives Act. AB
943 was held on this Committee's Suspense file.
6)Prior Legislation :
a) AB 2582 (Nestande), of the 2012 Legislative Session,
would have provided a tax credit for contributions to
public school co-curricular activities, to an educational
improvement organization that supports innovative programs
in public schools, as specified, or to an educational
scholarship organization. AB 2582 was never heard by this
Committee.
b) SB 1542 (Negrete-McLeod), of the 2011-12 Legislative
Session, would have created an income tax credit for
contributions made to a local educational advancement
program organization. SB 1542 was never by this Committee.
c) AB 279 (Duvall), of the 2009-10 Legislative Session,
would have allowed a tax credit for taxable years beginning
on and after January 1, 2010, equal to the amount of the
total contribution made by a qualified taxpayer to a
scholarship granting organization during the taxable year.
AB 279 was held on this Committee's Suspense File.
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d) AB 2605 (Nakanishi), of the 2007-08 Legislative Session,
would have allowed a personal income tax credit to
qualified taxpayers for each dependent attending a
nonpublic school. AB 2605 was held on this Committee's
Suspense File.
e) AB 2561 (Niello), of the 2007-08 Legislative Session,
would have provided an income tax credit for costs paid or
incurred for private school tuition. AB 2561 was on this
Committee's Suspense File.
f) SB 1768 (Hollingsworth), of the 2005-06 Legislative
Session, would have provided an income tax credit for
contributions made to a school tuition organization or a
public school. SB 1768 died in the Senate Revenue and
Taxation Committee
REGISTERED SUPPORT / OPPOSITION :
Support
California Association of Private School Organizations
California Catholic Conference
National Association for the Education of Homeless Children and
Youth
Opposition
American Civil Liberties Union
Americans United for the Separation of Church and State,
Sacramento Chapter
California Teachers Association
Analysis Prepared by : Carlos Anguiano / REV. & TAX. / (916)
319-2098