BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 94
                                                                  Page  1

          CONCURRENCE IN SENATE AMENDMENTS
          AB 94 (Evans)
          As Amended  September 1, 2009
          Majority vote
           
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          |ASSEMBLY:  |70-7 |(June 1, 2009)  |SENATE: |24-12|(September 3,  |
          |           |     |                |        |     |2009)          |
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           Original Committee Reference:    REV. & TAX.  

           SUMMARY  :  Reauthorizes the awarding of tax credits under the  
          Natural Heritage Preservation Tax Credit Act of 2000 (Act)  
          through fiscal year (FY) 2014-15.  

           The Senate amendments  :

          1)Reauthorize the awarding of tax credits under the Act through  
            FY 2014-15, instead of FY 2018-19.

          2)Adopt technical language suggested by the Franchise Tax Board  
            (FTB) to clarify the dates for which the credit is available.   
            Clarify that credits shall be allowed for qualified  
            contributions made on or after January 1, 2000, and not later  
            than June 30, 2008, and on or after January 1, 2010, and not  
            later than June 30, 2015.  
           
          EXISTING LAW  :

          1)Establishes the Wildlife Conservation Board (WCB).  The WCB is  
            charged with authorizing and allocating funds for the purchase  
            of property suitable for recreation and the preservation,  
            protection and restoration of wildlife habitat.  

          2)Requires the WCB to implement the Natural Heritage  
            Preservation Tax Credit Program (Program).  Under the Program,  
            upon the WCB's approval, a "donor" may contribute qualified  
            property to a "donee" and receive a nonrefundable tax credit  
            equal to 55% of the fair market value of any qualified  
            contribution of property made on or before June 30, 2008.  

          3)Limits the total amount of tax credits that can be awarded  
            under the Act to $100 million and prohibits tax credits from  
            being awarded after FY 2007-08 without further statutory  








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            authorization.

           AS PASSED BY THE ASSEMBLY  , this bill:

          1)Deleted the provisions of the Act that:

             a)   Limit the total amount of tax credits that can be  
               awarded under the Act to $100 million; and, 

             b)   Prohibit tax credits from being awarded after FY 2007-08  
               without further statutory authorization.    

          2)Provided that tax credits may be awarded under the Act only if  
            the amount of all lost revenue resulting from the award of tax  
            credits was reimbursed by transfer to the General Fund (GF) of  
            "moneys that are not from the GF."  

          3)Defined "moneys that are not from the GF" as any of the  
            following:

             a)   State bond funds as described in Public Resources Code  
               (PRC) Section 37032;

             b)   State funds available for the purposes of the Act, other  
               than funds specified in PRC Section 37014;

             c)   Court settlements;

             d)   Private or public donations;

             e)   Local government funds of any type; or, 

             f)   Federal funds available for the purposes of the Act.  

          4)Expanded the Act's definition of "donee" to include a local  
            government that has submitted an application directly to the  
            WCB. 

          5)Provided that, if a local government applies directly to the  
            WCB for acceptance of a qualified donation, the WCB may  
            provide conditional approval for the local government to  
            acquire the property under the Act.  The local government  
            shall reimburse the GF for the tax credit claimed by  
            transferring funds in the full amount of the approved tax  
            credit to the WCB for deposit into the Natural Heritage  








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            Preservation Tax Credit Reimbursement Account.

          6)Provided that, if a local government applies directly to the  
            WCB for acceptance of a qualified donation, and the WCB  
            provides conditional approval, the local government shall have  
            60 days to transfer to the WCB the full amount of funds  
            necessary to reimburse the GF.  Upon receipt of these funds,  
            the WCB shall provide the donor and the local government with  
            a notice of final approval of the tax credit.  

          7)Specified that the information the FTB provides the WCB on tax  
            credits claimed shall include the tax year for which the  
            credit was claimed.  

          8)Provided that, if a local government applies for a designated  
            nonprofit organization to acquire and accept donated property,  
            the local government shall comply with all requirements of the  
            Act that apply to the local government transferring funds to  
            the WCB necessary to reimburse the GF.  

          9)Amended the definition of "displaced person" contained in the  
            Government Code chapter that provides for relocation  
            assistance to those displaced by a public entity.   
            Specifically, specified that a "displaced person" shall not  
            include "[a]ny person who donates or willingly sells his or  
            her property for the purposes of protecting fish and wildlife  
            habitat, providing recreational areas, or preserving cultural  
            or agricultural resources and open space and any person who  
            occupies that property on a rental basis."  However, this  
            exclusion does not apply when a sale is in response to an  
            eminent domain proceeding.  

          10)Made certain technical and non-substantive changes to the  
            Act. 

           FISCAL EFFECT  :  According to the Assembly Appropriations  
          Committee:

          1)No direct impact on the GF as the credits (estimated by FTB to  
            be about $7 million per year) are fully reimbursed by bond  
            funds, federal or local funds, donations, or other sources,  
            all of which could be used for other purposes, absent this  
            program.

          2)Potential reallocation of tens of millions of Proposition 84  








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            bond funds, to the extent the funds currently authorized to be  
            used to reimburse the GF for the credits would be available  
            for other purposes absent the reauthorization of this program.

          3)Minor indirect impact (initially in the range of $20,000 per  
            year and growing over time) on GF expenditures to backfill  
            schools for reduced property taxes, to the extent that the  
            credit results in a higher level of land donations and, hence,  
            a reduced property tax roll.

           COMMENTS :  The author states, "With a continually expanding  
          population, California needs to preserve land, restore habitats,  
          and protect water supplies.  However, we are also facing  
          uncertain fiscal times, where every dollar of previously  
          approved bonds must be maximized.  This bill would extend a  
          'financial tool' that can save 45% on the purchase price  if  the  
          state or local agency chooses to use the tax credit program to  
          acquire recreation or habitat lands AND  if  the landowner agrees.  
           Effectively, this voluntary program allows California to  
          acquire $18 million of land for every $10 million of bond  
          funding, while providing fair value to the landowner, and  
          keeping the General Fund whole.  During its previous  
          authorization period, the Natural Heritage Preservation Tax  
          Credit saved California approximately $40 million in the  
          acquisition of more than 8,000 acres of land in Calaveras, Lake,  
          Los Angeles, Madera, Marin, Monterey, Sacramento, San Luis  
          Obispo, Santa Barbara, Tehama, and Ventura Counties.  This bill  
          would allow the state to once again work with interested  
          landowners to provide a legacy for future generations of  
          Californians."  

          Committee Staff Comments:

          1)A Different Kind of Credit.

             a)   Credits are used to reduce the amount of taxes a  
               taxpayer owes.  Typically, the Legislature enacts tax  
               credits to encourage socially beneficial behavior.  Thus,  
               credit amounts are usually based on a percentage of  
               specified costs incurred by the taxpayer.  In the present  
               case, the amount of the credit is equal to 55% of the fair  
               market value of land donated.  

             b)   Tax credits can either be nonrefundable or refundable.   
               Nonrefundable credits, like those authorized by the Act,  








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               work only to reduce a taxpayer's tax liability.  Usually,  
               any remaining credit amount left after reducing the  
               taxpayer's liability to zero can be carried forward to  
               offset the taxpayer's tax liability in future years.  With  
               a refundable credit, however, the state must refund the  
               remaining value of the credit after tax due is reduced to  
               zero.  It should be noted that nonrefundable credits rarely  
               help lower-income taxpayers because these taxpayers have  
               little or no tax liability to offset. 

             c)   The Natural Heritage Preservation Tax Credit operates  
               differently from other tax credits.  Specifically, these  
               credits are funded by bond funds, private donations, and  
               other specified moneys, instead of foregone tax revenues  
               that would normally flow to the GF.  Because these credits  
               have no direct impact on the GF, this bill removes the  
               current $100 million cap contained in the Act.  


           Analysis Prepared by  :  M. David Ruff / REV. & TAX. / (916)  
          319-2098 


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