BILL ANALYSIS                                                                                                                                                                                                    �




                     SENATE GOVERNANCE & FINANCE COMMITTEE
                            Senator Lois Wolk, Chair
          

          BILL NO:  SB 235                      HEARING:  5/15/13
          AUTHOR:  Wyland                       FISCAL:  Yes
          VERSION:  5/8/13                      TAX LEVY:  Yes
          CONSULTANT:  Miller                   

                                        
          

          Includes seven provisions to reduce taxes in the personal  
          income, corporate and sales and use taxes. 


                    Background, Existing Law and Proposed Law  

          I.  Corporate and Income Tax: general  
          Existing state and federal laws provide various tax credits  
          designed to provide tax relief for taxpayers who incur  
          certain expenses (e.g., child adoption) or to influence  
          behavior, including business practices and decisions (e.g.,  
          research credits or economic development area hiring  
          credits).  These credits generally are designed to provide  
          incentives for taxpayers to perform various actions or  
          activities that they may not otherwise undertake.


          For a ten-year period ending December 31, 2003, California  
          law provided a partial (General Fund only) sales and use  
          tax exemption for purchases of equipment and machinery by  
          new manufacturers, and income and corporation tax credits  
          for existing manufacturers' investments (MIC) in equipment  
          (SB 671, Alquist, 1993).  The bill provided an exemption to  
          the state portion of the sales and use tax for sales and  
          purchases of qualifying property, and the income tax credit  
          equal to six percent of the amount paid for qualified  
          property placed in service in California.  Qualified  
          property was depreciable equipment used primarily for  
          manufacturing, refining, processing, fabricating or  
          recycling; for research and development; for maintenance,  
          repair, measurement or testing of qualified property; and  
          for pollution control meeting state or federal standards.  

          The MIC had a conditional sunset date which required that  
          the provisions sunset in any year following a year when  
          manufacturing employment (as determined by the Employment  




          SB 235 -- 5/8/13 -- Page 2



          Development Department) did not manufacturing employment by  
          more than 100,000.  On January 1, 2003, manufacturing  
          employment, less aerospace, did not exceed the 1994  
          employment number by more than 100,000 (it was less than  
          the 1994 number by over 10,000), and so the MIC and partial  
          sales tax exemption sunset at the end of 2003. 

          Since then, over 19 bills have been introduced to  
          reinstate, expand, or modify the exemption and/or MIC, but  
          all failed to pass.  

          II.   Sales Tax
           Existing law does not currently provide special tax  
          treatment to firms that purchase equipment and other  
          supplies; business pay sales and use tax on their purchases  
          as any consumer would.

          The state sales and use tax rate is 7.50% as detailed  
          below.  Cities and Counties may increase the sales and use  
          tax rate up to 2% for either specific or general purposes  
          with a vote of the people. 


          
                   ------------------------------------------------------------- 
                  |       |                    |                                |
                  | Rate  |    Jurisdiction    |       Purpose/Authority        |
                  |       |                    |                                |
                  |-------+--------------------+--------------------------------|
                  |       |                    |                                |
                  |3.9375%|State (General      |State general purposes          |
                  |       |Fund)               |                                |
                  |       |                    |                                |
                  |-------+--------------------+--------------------------------|
                  |       |                    |                                |
                  |1.0625%|Local Revenue Fund  |Realignment of local public     |
                  |       |2011                |safety services                 |
                  |       |                    |                                |
                  |       |                    |                                |
                  |       |                    |                                |
                  |-------+--------------------+--------------------------------|
                  |       |                    |                                |
                  | 0.25% |State (Fiscal       |Repayment of the Economic       |
                  |       |Recovery Fund)      |Recovery Bonds                  |
                  |       |                    |                                |
                  |-------+--------------------+--------------------------------|





          SB 235 -- 5/8/13 -- Page 3



                  |       |                    |                                |
                  | 0.25% |State (Education    |Schools and community college   |
                  |       |Protection Account) |funding                         |
                  |       |                    |                                |
                  |-------+--------------------+--------------------------------|
                  |       |                    |                                |
                  | 0.50% |State (Local        |Local governments to fund       |
                  |       |Revenue Fund)       |health and welfare programs     |
                  |       |                    |                                |
                  |-------+--------------------+--------------------------------|
                  |       |                    |                                |
                  | 0.50% |State (Local Public |Local governments to fund       |
                  |       |Safety Fund)        |public safety services          |
                  |       |                    |                                |
                  |-------+--------------------+--------------------------------|
                  |       |                    |                                |
                  | 1.00% |Local (City/County) |City and county general         |
                  |       |                    |operations. Dedicated to county |
                  |       |                    |transportation purposes         |
                  |       |0.75% City and      |                                |
                  |       |County              |                                |
                  |       |                    |                                |
                  |       |0.25% County        |                                |
                  |-------+--------------------+--------------------------------|
                  |       |                    |                                |
                  | 7.50% |Total Statewide     |                                |
                  |       |Rate                |                                |
                  |       |                    |                                |
                   ------------------------------------------------------------- 
                  
          Many items are fully exempted from the sales and use tax in  
          this state (prescription drugs, food, poultry litter) but  
          only a handful are partially exempted from the sales tax at  
          the rate of 5.5%; specifically: Farm equipment and  
          machinery; Diesel fuel used for farming and food  
          processing; Teleproduction and postproduction equipment;  
          Timber harvesting equipment and machinery; and Racehorse  
          breeding stock. 

          SB 235, beginning January 1, 2014, provides a 3.9375% state  
          sales and use tax exemption for a "qualified person's"  
          purchase of manufacturing, research and development, and  
          construction.  The bill defines a qualified person pursuant  
          to the North American Industry Classification System  
          (NAICS) to include a trade, business or affiliate primarily  
          engaged in manufacturing. 





          SB 235 -- 5/8/13 -- Page 4





          SB 235 defines "fabricating," "manufacturing," "primarily,"  
          "process," "processing," "refining," "research and  
          development," and "useful life."  The bill also specifies  
          the tangible personal property included or excluded from  
          the partial exemption.

           
           III.   Research and Development Credit  
          Existing federal law allows taxpayers a research credit  
          that is combined with several other credits to form the  
          general business credit designed to encourage companies to  
          increase these activities.  

          The research credit is determined as the sum of: 

             1.   20 percent of the qualified research expenses  
               incurred during the taxable year that exceeds the base  
               amount, and 

             2.   20 percent of the amount paid or incurred during  
               the taxable year on research undertaken by an energy  
               research consortium. 

          Corporate taxpayers, in addition to the two components  
          listed above, are allowed to include 20 percent of expenses  
          paid to fund basic research at universities and certain  
          nonprofit scientific research organizations. 

          For taxable years beginning before January 1, 2008, instead  
          of determining the credit based on 20 percent of qualified  
          research expenses in excess of a base amount, a taxpayer  
          could elect to calculate the credit using a different  
          method, known as the "Alternative Incremental Credit"  
          (AIC).  Taxpayers claiming the AIC instead use graduated  
          percentages of 3 percent, 4 percent, and 5 percent, as  
          applied to a percentage of expenses in excess of a  
          specified percentage of average annual gross receipts.   
          This method is no longer available for federal purposes.

          To qualify for the credit, research expenses must be  
          conducted in the US, be experimental or laboratory research  
          and pass a three-part test:  

             1.   Research must be undertaken to discover information  





          SB 235 -- 5/8/13 -- Page 5



               that is technological in nature and relate to  
               biological, engineering, or computer sciences. 

             2.   Substantially all of the research activities must  
               involve experimentation relating to quality or to a  
               new or improved function or performance. 

             3.   The application of the research must be intended  
               for developing a new business component such as a  
               product, process, technique, formula, or invention. 

          Ineligible expenses include: seasonal design factors;  
          efficiency surveys; management studies; market research;  
          routine data control; routine quality control testing or  
          inspection; expenses incurred after production; development  
          of any plant, process, machinery, or technique for the  
          commercial production of a business component unless the  
          process is technologically new or improved.  

          California conforms to the federal credit with the  
          following modifications: 


                 The state credit is not combined with other  
               business credits. 

                 Research must be conducted in California. 

                 The credit percentage for qualified research in  
               California is 15 percent versus the 20 percent for the  
               federal credit. 

                 The credit percentage for basic research in  
               California is limited to corporations (other than S  
               Corporations, personal holding companies, and service  
               organizations) and is 24 percent versus the 20 percent  
               federal credit. 

                 Gross receipts is modified to take into account  
               only those gross receipts from the sale of property  
               held primarily for sale to customers in the ordinary  
               course of the taxpayer's trade or business that is  
               delivered or shipped to a purchaser within this state,  
               regardless of freight on board point or any other  
               condition of sale.






          SB 235 -- 5/8/13 -- Page 6



                 The AIC is available for taxable years beginning on  
               or after January 1, 2008, but the percentages of 3  
               percent, 4 percent, and 5 percent are reduced to 1.49  
               percent, 1.98 percent, and 2.48 percent, respectively.


          SB 235 increases the Research & Development credit for tax  
          years beginning on or after January 1, 2014 to:

                 Increase the credit rate to 20 percent for  
               qualified research.

                 Continue to allow the election of the AIC.

          For taxable years beginning on or after January 1, 2010, SB  
          235 modifies the California rates to use the federal  
          percentages rules for the AIC.



          IV.   Jobs Credits
           California allows two hiring credits: (1) The New Jobs  
          Credit and (2) The Enterprise Zone Hiring Credit.  

          1.  New Jobs credit  enacted in 2009 to qualified employers  
          equal to $3000 for each net increase in qualified full-time  
          employees hired during the taxable year. The credit is  
          limited to small businesses with 20 or fewer employees.  As  
          of April 6, 2013, the total number of Personal Income Tax  
          and Business Entity returns claiming the New Jobs Tax  
          Credit was 27,417 and the amount of credits claimed totaled  
          $155.5 million.  The cut-off date will be the last day of  
          the calendar quarter within which the FTB estimates it will  
          have received timely filed original returns claiming the  
          credit that cumulatively total $400 million.


          2.  Enterprise zone hiring credit  .  Employers inside an  
          enterprise zone may claim a tax credit of 50% of the wages  
          paid to a qualified employee in the first year, 40% in the  
          second year, 30% in the third year, 20% in the fourth year,  
          and 10% in the fifth year, up to 150% of the minimum wage.   
          Businesses or consultants submit applications to qualify  
          employees to zone managers, who grant the firm or  
          consultant a voucher certifying eligibility if the employee  
          qualifies.  The firm then claims the credit on its tax  





          SB 235 -- 5/8/13 -- Page 7



          return.  Qualified employees include individuals: 

                           Eligible for job training programs
                           Eligible for most social welfare programs
                           Economically disadvantaged
                           A "dislocated worker," as defined.
                           A disabled individual who is eligible or  
                    enrolled in a state rehabilitation plan
                           Service connected veteran
                           Ex-offender
                           Member of a federally recognized Indian  
                    tribe

          Employers may also claim the hiring credit for residents of  
          Targeted Employment Areas (TEAs), in addition to the  
          criteria listed above.  Cities and counties managing  
          enterprise zones may draw TEAs to contain census tracts  
          where 51% or more of the individuals are low or moderate  
          income, meaning 80% of the area wide, or countywide,  
          median.  In other words, local agencies draw TEAs to  
          include communities where only half of the residents are  
          actually or somewhat low-income, but anyone living in one  
          qualifies his or her employers for the hiring credit  
          regardless of their own economic status or employability.   
          TEAs need not be contiguous to, or drawn within the borders  
          of the Enterprise Zone.

          Taxpayers can also receive a certification qualifying an  
          employee for an enterprise zone hiring credit at any time.   
          Taxpayers may certify employees who worked for them in past  
          years, then submit claims for refunds for previous taxes  
          paid to FTB based on those certifications under  
          California's general four year statute of limitations for  
          amending past returns, a practice known as  
          "retro-vouchering."  In general, tax law allows taxpayers  
          to amend their returns for four years.  SB 974 (Steinberg,  
          2010) and AB 1139 (Perez, 2009) proposed to repeal the TEA  
          criterion and "retro vouchering," although neither bill  
          advanced to the Governor's Desk.
          
          SB 235 grants a tax credit for the first $6,000 of wages as  
          follows:

                 25 percent for each employee that is employed for  
               at least 120 hours, but less than 400 hours. 






          SB 235 -- 5/8/13 -- Page 8



                 40 percent for an employee that is employed for at  
               least 400 hours. 


          Wages included in the calculation of any other deduction or  
          credits otherwise allowed are excluded from the calculation  
          of this credit.   SB 235 defines its terms including  
          "Qualified employee" to mean any of the following, to be  
          documented by the Employment Development Department (EDD): 

                  o         A recipient of CalWORKs benefits.

                  o         A parolee.

                  o         A veteran, as defined in Section 980 of  
                    the Military and Veterans Code.

                  o         An eligible recipient of unemployment  
                    insurance benefits or currently receiving  
                    unemployment insurance benefits.  

                  o         A person on probation.   



          SB 235 specifies the functionality of the credit including  
          the voucher provisions.  

          

          SB 235 also revises the New Jobs Credit from 2009 by  
          eliminating the following:

                 The requirement that the employer have 20 or fewer  
               employees

                 The specified cap of $400 million and all  
               provisions related to tracking the cap

                 FTBs obligation to post utilization data on its  
               website 

                 The requirement that the credit may only be filed  
               on the original timely filed return







          SB 235 -- 5/8/13 -- Page 9



          V.   Net Operating Losses (NOL)  

          Federal law generally defines an NOL as the excess of  
          deductions allowed over the gross income.  When a taxpayer  
          has an operating loss for a taxable year, the operating  
          loss that may be deducted in subsequent years is called an  
          NOL.  An operating loss occurs when a taxpayer's allowed  
          deductions exceed their gross income for that year.   
          Federal law provides, in general, that an NOL can be  
          carried back 2 years and forward 20 years and deducted.   
          Special rules are provided for the carryback of NOLs  
          relating to issues such as specified liability losses,  
          casualty or theft losses, disaster losses of a small  
          business, and farming losses.  
           
           In general, a California taxpayer calculates its NOL in  
          accordance with federal rules.  NOLs attributable to  
          taxable years beginning on or after January 1, 2008, may be  
          carried forward 20 years.  For NOLs attributable to taxable  
          years beginning before January 1, 2013, NOL carrybacks are  
          unavailable.  California conforms to the federal NOL  
          carryback rules for NOLs attributable to taxable years  
          beginning on or after January 1, 2013, with the following  
          modifications: 

             1.   An NOL may be carried back only 2 years. (Federal  
               law has special rules that in some cases allow an NOL  
               to be carried back for a longer period). 

             2.   The amount of an NOL carryback attributable to  
               taxable year 2013 is limited to 50 percent of the NOL.  


             3.   The amount of an NOL carryback attributable to  
               taxable year 2014 is limited to 75 percent of the NOL.  


             4.   The amount of an NOL carryback attributable to  
               taxable year 2015 and thereafter is 100 percent of the  
               NOL. 

          NOL deductions were suspended for taxable years 2008  
          through 2011.  For taxable years 2010 and 2011, the  
          suspension applied to taxpayers with modified adjusted  
          gross income of $300,000 or more.  






          SB 235 -- 5/8/13 -- Page 10



          SB 235 increases the allowable carryback percentage from 75  
          percent to 100 percent for NOLs attributable to taxable  
          year 2014.  

          VI.   Capital Gains  

          The Internal Revenue Code provide the rules governing the  
          tax treatment of capital gains and losses, identifying  
          holding periods, and determining the gain or loss from the  
          sale or exchange of a capital asset.  In general, property  
          held for personal use or investment purposes is a capital  
          asset.  Examples of capital assets include  
          held-for-investment stocks and securities as well as an  
          owner-occupied personal residence.  Property used in a  
          taxpayer's trade or business is not a capital asset. When a  
          capital asset is sold or exchanged, the difference between  
          the selling price and the asset's adjusted basis, which is  
          usually what was paid for the asset, is a capital gain or  
          loss.  

          Under federal law, there are circumstances when a  
          percentage of a capital gain may be excluded from a  
          taxpayer's gross income.  For example, federal law allows a  
          capital gain exclusion from the sale of a personal  
          residence.  An individual may exclude up to $250,000 of  
          gain, while a married couple filing a joint return may  
          exclude up to $500,000.  

          Complex rules allow non-corporate taxpayers to apply  
          maximum tax rates from 0 percent to 28 percent to the  
          taxation of a net capital gain, whereas for corporate  
          taxpayers, capital gains are taxed as ordinary income tax  
          rates. 

          Generally, capital gains and losses are classified as  
          long-term or short-term, depending on how long the property  
          was held before it was sold.  Current federal law provides  
          that property held more than one year will result in  
          long-term capital gain or loss. If the property is held  
          less than a year, the capital gain or loss is short-term.   
          These distinctions are essential to arrive at the correct  
          amount of net capital gain or loss.  

          "Net capital gain" means the excess of the net long-term  
          capital gain for the taxable year over the net short-term  
          capital loss for such year.  When calculating the net  





          SB 235 -- 5/8/13 -- Page 11



          capital gain. 

          California law generally follows the federal rules for  
          defining capital assets, identifying holding periods, and  
          determining the gain or loss from the sale or exchange of a  
          capital asset.  Capital gains are taxed as ordinary income  
          tax rates under personal income tax law.

          SB 235 excludes any gain from the sale of an asset from  
          gross income. 

          
          VII.  Depreciation

          "Depreciation" is the term generally used to describe any  
          method of recovering (commonly referred to as "expensing")  
          the cost of an asset, across its useful life, roughly  
          corresponding to normal wear and tear.  For tax purposes,  
          "depreciation" is an income tax deduction that allows a  
          taxpayer to recover (i.e., "expense") the cost or other  
          basis of certain property that is used in a business or  
          used in an income-producing activity.  Most types of  
          tangible property other than land are depreciable, such as  
          buildings, machinery, vehicles, furniture, and equipment.   
          Likewise, certain intangible property, such as patents,  
          copyrights, and computer software, are also depreciable.   
          Taxpayers may also depreciate capital improvements to  
          property that they lease.  

          Depreciation begins when a taxpayer places property in  
          service for use in a trade or business or for the  
          production of income.  The property ceases to be  
          depreciable when the taxpayer has fully recovered the  
          property's cost or other basis or when the taxpayer retires  
          it from service, whichever happens first.  There are  
          complex state and federal rules on expensing and  
          depreciation.

          SB 235 requires all California taxpayers to depreciate  
          property using the following recovery periods: 

                 For property placed in service on or after January  
                                                           1, 2014, the applicable recovery period is one-half of  
               the recovery period otherwise allowable under state  
               law, or one-half- of the recovery period allowable  
               under federal law as in effect on January 1, 2009





          SB 235 -- 5/8/13 -- Page 12




                 For property placed in service before January 1,  
               2014, taxpayers are allowed either to use the  
               remaining recovery period to depreciate that property  
               under the recovery period already being used, or elect  
               to use a recovery period of one-half of the recovery  
               period otherwise allowable under state law, or  
               one-half of any recovery period allowable under  
               federal law as in effect on January 1, 2009, for the  
               remaining depreciable costs of such property.  

                               State Revenue Impact
           
          The FTB and BOE provide the following estimates:

          
                -------------------------------------------------------------------- 
               |                           ($ in Millions)                          |
                -------------------------------------------------------------------- 
               |----------+-----------+-----------+------------+------------+---------|
               |   Fiscal |  2013-14  |  2014-15  |  2015-16   |  2016-17   | 2017-18 |
               |      Year|           |           |            |            |         |
               |----------+-----------+-----------+------------+------------+---------|
               |Sales &   |   -302    |   -642    |    -686    |            |         |
               |Use Tax   |           |           |            |            |         |
               |----------+-----------+-----------+------------+------------+---------|
               |Research  |  - $150   |   - $90   |   - $180   |   - $190   | - $190  |
               |Credit    |           |           |            |            |         |
               |----------+-----------+-----------+------------+------------+---------|
               |New Jobs  |  - $900   | - $3,600  |  - $5,000  |  - $4,600  |-        |
               |and       |           |           |            |            |    $4,800|
               |Targeted  |           |           |            |            |         |
               |Employees |           |           |            |            |         |
               |Credit    |           |           |            |            |         |
               |----------+-----------+-----------+------------+------------+---------|
               |NOL       |    $0     |   - $1    |   - $13    |    + $4    |  + $4   |
               |Carryback |           |           |            |            |         |
               |----------+-----------+-----------+------------+------------+---------|
               |Accelerate| - $1,000  | - $2,200  |  - $2,000  |  - $1,500  |-        |
               |d         |           |           |            |            |$1,300   |
               |Depreciati|           |           |            |            |         |
               |on        |           |           |            |            |         |
               |----------+-----------+-----------+------------+------------+---------|
               |Capital   | - $4,500  | - $3,500  |  - $5,500  |  - $5,500  |- $6,000 |
               |Gains     |           |           |            |            |         |
               |Exclusion |           |           |            |            |         |





          SB 235 -- 5/8/13 -- Page 13



               |----------+-----------+-----------+------------+------------+---------|
               |Total     | - $6,802  | - $10,142 | - $13,686  | - $12,000  |-        |
               |Impact    |           |           |            |            |$12,000  |
               |(Rounded)*|           |           |            |            |         |
               |          |           |           |            |            |         |
                ---------------------------------------------------------------------- 
            *May not add due to rounding.


                                     Comments  

          1.   Purpose of the bill  .  The author provides the following  
          statement in support of the bill: "There are nearly two  
          million Californians out of work, and California's  
          unemployment rate is among the highest in the nation. In  
          addition, California has a struggling economy and a  
          business environment that discourages economic growth. As  
          such, California needs bold reforms. The Legislature must  
          enact policies that provide incentives for job creation  
          that entices businesses to hire new employees.  SB 235 will  
          encourage job creation and investment here in California by  
          enacting a sales and use tax exemption for manufacturing  
          equipment, eliminating the state tax on capital gains,  
          establishing hiring credits for new employees, increasing  
          the research and development credit, shortening  
          depreciation schedules, and expanding the current net  
          operating loss deduction rules." 


          2.   Where's the proof  ?  The author's intent is to spur  
          economic development and increase the productivity in the  
          state under the assumption that lower taxes create jobs and  
          increase the state's economic output.  Most economists  
          agree that the best tax policy is to lower the rates and  
          broaden the base thereby creating a more equitable system  
          in general.  They also agree that targeted tax credits  
          rarely work and are a poor substitute for direct subsidies  
          that create a multiplier effect for the disadvantaged.   
          Since at least 1936, when Cambridge University economists  
          Arthur Pigou and Nicholas Kaldor debated the use of wage  
          subsidies to alleviate unemployment, academics and policy  
          analysts have been arguing over the idea.  In 1977,  
          Congress enacted the New Jobs Tax Credit, offering a tax  
          benefit to any company that increased its payroll by more  
          than 2 percent.  One study said that it worked and  
          increased employment at some firms by almost 3% but all  





          SB 235 -- 5/8/13 -- Page 14



          others said it didn't work and in some cases reduced  
          employment because "demand wasn't there."  The conclusions  
          on state only tax credits are even gloomier and less likely  
          to have any tangible result.  A report by the Pew Center in  
          April, 2012 on the states that have tax credits say that it  
          is impossible to know if they work because half the states  
          that have incentives have not taken the basic steps needed  
          to know whether their incentives are effective.  The  
          Committee may wish to consider whether SB 235's provisions  
          are clearly thought through in terms of their long term  
          impact, efficacy and outcomes.  


          3.   The economist speaks  .   Again, most economists agree  
          that the best tax policy for any state is to reduce rates  
          and broaden the base and not to target tax credits.  While  
          still a costly provision, the idea is that a product is  
          only taxed once, when sold, instead of taxing all inputs  
          and outputs as well.  The only provision of SB 235 that is  
          commensurate with economic theory is the sales and use tax  
          exemption for manufacturing (with amendments). On April  
          24th, this Committee passed SB 394 (Correa), which exempted  
          manufacturing equipment from the state share of the sales  
          tax.  The Committee may wish to amend that bill to delete  
          all other provisions and only include the sales and use tax  
          exemption for manufacturing.  

           4.  The sun also sets  .  Some bills granting tax benefits  
          set forth an economic indicator or series of economic  
          indicators that its author expects will improve as a result  
          of a tax credit.  For example, bills heard by the Committee  
          exempting manufacturing equipment from the sales tax have  
          used:
                 Increased employment for manufacturing, research   
               and development, and associated industries,
                 Siting for new and expanded manufacturing and  
               research and development facilities in this state,
                 Capital investment in manufacturing equipment and  
               all other tangible personal property.

          As the Pew Foundation points out, it's impossible to know  
          if tax credits work because states do not collect data.   
          The Committee may wish to amend SB 235 to include both  
          performance measurers and a modest sunset.  

           5.  Hindsight is 20/20  .  The Research and Development  





          SB 235 -- 5/8/13 -- Page 15



          provisions of SB 235 increase the AIC rates, retroactively,  
          to January 1, 2010.  This could result in numerous  
          taxpayers filing amended returns to claim the higher rates  
          for returns with open statutes of limitation.  Taxpayers  
          argue that tax agencies retroactively send notices of  
          proposed assessments but do not argue that a retroactive  
          tax break is inappropriate.  

          6.   Mean what you say  .  SB 235 leaves many terms undefined  
          including: 
                 "Wages" and "qualified wages" are not defined which  
               will lead to disputes with taxpayers and complicate  
               its administration.  
                 The jobs credit does not specify the length of time  
               the taxpayer may take the credit for the employee  
               which could lead to an indefinite credit for each  
               employee.  
                 The depreciation provisions are silent on how and  
               when an election would be made to change the remaining  
               recovery period.  The provision is also silent on  
               whether the election would be irrevocable.  The  
               absence of guidance could lead to disputes with  
               taxpayers and would complicate the administration of  
               this provision. 
                 The term "property" should be clarified to mean  
               "tangible personal property"
                 The bill goes beyond manufacturing for the sales  
               and use tax exemption and should be restricted to  
               business primarily engaged in manufacturing.
                 The bill does not define "affiliates" which could  
               lead to abuse and more taxpayers than intended  
               receiving credits.

          7.   Not so fast  .  SB 235 restricts wages included in the  
          calculation of the credit to wages paid for services  
          performed in California.  This provision could raise  
          constitutional concerns under the Commerce Clause of the  
          United States Constitution because it could appear to  
          improperly favor in-state activity over out-of-state  
          activity.  On August 28, 2012, (Cutler v. Franchise Tax  
          Board), the Court of Appeal issued a unanimous opinion  
          holding that California's Qualified Small Business Stock  
          statutes were unconstitutional.  Specifically, the Court of  
          Appeal held that the statutory scheme's requirement of a  
          large California presence in order to qualify for an  
          investment incentive discriminated against interstate  





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          commerce, and therefore violated the federal dormant  
          commerce clause.  While no court decision has yet  
          invalidated, as a general matter, state income tax credits  
          that provide an incentive for in-state activity, i.e.,  
          property placed in service in the state, employees employed  
          in the state, etc., targeted tax credits such as the one  
          proposed by this bill may be subject to constitutional  
          challenge.  The Committee may wish to consider the  
          Constitutionality of in-state tax credits so as to mitigate  
          legal challenges in the future.  

          8.   The goose that laid the golden egg & Martin Helmke  .   
          Proponents of capital gains reductions argue that the state  
          has been entirely too dependent on high income individuals  
          to fund the state's personal income tax revenue.  In 2011,  
          the top 10-percent of income earners paid more than 78.5%  
          of the personal income tax revenue.  This "boom and bust"  
          cycle along with the budget requirements for spending has  
          created volatility in the state's general fund.  The  
          question of volatility, however, is not black and white.  A  
          long-time Revenue & Taxation committee consultant, Martin  
          Helmke compared the state's volatility to the parable of  
          the goose that laid the golden egg.  Every few years  
          California's goose would lay a golden egg and we all enjoy  
          it; when the goose does not lay the golden egg, we speak  
          about killing it.  Does it make more sense to kill the  
          goose or simply to save the eggs?  


          9.   How high can you go  ?  California affords taxpayers the  
          highest Research and Development Credit in the nation  
          arguably because our competitive advantage lies in advanced  
          research.  Only two other states come close to California's  
          percentages, Massachusetts and New York but each state has  
          strict limits and sunsets whereas California has neither  
          performance measures associated with the credit nor a  
          sunset.

          Massachusetts allows corporate taxpayers to claim an excise  
          tax credit for qualified expenditures that are used for  
          increasing research activities in Massachusetts.  The  
          credit is 15 percent of the basic research payments and 10  
          percent of qualified research expenses conducted in  
          Massachusetts.  The credit sunsets in 2018.  New York  
          allows a credit for qualified emerging technology  
          companies.  The credit is equal to 18 percent of the cost  





          SB 235 -- 5/8/13 -- Page 17



          of research and development property, 9 percent of the  
          qualified research expenses, and the cost of qualified  
          high-technology training expenditures, limited to $4,000  
          per employee, per year.  The credit is limited to $250,000  
          per taxable year.  The Committee may wish to consider if it  
          makes sense to increase the richest tax credit in the state  
          without evaluating its efficacy for economic development,  
          job creation and innovation.


          10.   Which side are you on  ? Proponents of measures such as  
          SB 235 are generally considered "supply side economists"  
          and claim that if the top income earners invest more into  
          the business infrastructure and equity markets, it will in  
          turn lead to more goods at lower prices, and create more  
          jobs for middle and lower income individuals.  Proponents  
          argue economic growth flows down from the top to the  
          bottom, indirectly benefiting those who do not directly  
          benefit from the policy changes. However, others have  
          argued that "trickle-down" policies generally do not work,  
          and that the trickle-down effect might be very slim.   
          Opponents to measures like these are more closely related  
          to Keynesian economics which often criticize tax cuts for  
          the wealthy as being "trickle down," arguing that tax cuts  
          directly targeting those with less income would be more  
          economically simulative. Keynesians generally argue for  
          broad fiscal policies that are direct across the entire  
          economy, not toward one specific group. Supply-siders, on  
          the other hand, argue that tax cuts for the rich promote  
          investment, (basically the rich choosing where their money  
          goes, and then getting dividends in return) which in turn  
          promotes growth.  The Committee may wish to consider-rather  
          than choosing an economic theory to follow-what tax reform  
          should look like in California, what principles to pursue,  
          what data to collect and construct a new system  
          accordingly.  


          11.   Have we met before  ?  SB 1239 (Wyland, 2009) was almost  
          identical to this bill and failed passage in the Senate  
          Revenue & Taxation Committee.  


                         Support and Opposition  (5/9/13)

           Support  :  Arroyo Grande & Grover Beach Chamber of Commerce;  





          SB 235 -- 5/8/13 -- Page 18



          BOE Member George Runner; California Chamber of Commerce;  
          Vista Chamber of Commerce; .Industry Manufacturer's  
          Council.

           Opposition  :  California Teachers Association.