BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 765
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          Date of Hearing:  May 18, 2009

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                             Charles M. Calderon, Chair

                    AB 765 (Caballero) - As Amended:  May 13, 2009

          Majority vote.  Tax levy.  Fiscal committee.

           SUBJECT  :  Income tax credit:  purchase:  principal residence.

           SUMMARY  :  Extends the operative date of qualified principal  
          residence purchase credit from March 1, 2010 to December 1,  
          2010.  Increases the cap on the total amount of credit from $100  
          million to $300 million.  Specifically,  this bill :  

          1)Extends the time period within which a taxpayer may purchase a  
            qualified principal residence to qualify for the existing tax  
            credit from March 1, 2010 until December 1, 2010.

          2)Increases the existing cap on the total amount of credit that  
            may be claimed by taxpayers from $100 million to $300 million.  


          3)Specifies that purchases of qualified principal residence made  
            after March 1, 2010 and before December 1, 2010, must be  
            pursuant to an enforceable contract to purchase the qualified  
            principal residence executed prior to March 1, 2010. 

          4)Allows taxpayers to reserve the credit prior to the close of  
            escrow but requires the taxpayer and seller to jointly sign  
            and submit to the Franchise Tax Board (FTB) a certification  
            that they have entered into the sale agreement on or after  
            March 1, 2009, and before March 1, 2010.   

          5)Requires FTB to reserve the credit for the taxpayer upon  
            receipt of the joint certification and notify the taxpayer  
            about the conditional reservation. 

          6)Requires the seller to provide a certification of the  
            qualified principal residence within one week of the close of  
            escrow instead of the sale of the qualified principal  
            residence.

          7)Takes effect immediately as a tax levy.








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           EXISTING LAW  :

          1)Provides various tax credits designed to provide incentives  
            for taxpayers that incur certain expenses or to influence  
            behavior, including business practices and decisions. 

          2)Authorizes a tax credit for individual taxpayers who purchase  
            qualified personal residences after March 1, 2009 and before  
            March 1, 2010. 

          3)Limits the amount of credit to the lesser of 5% of the  
            purchase price or $10,000. 

          4)Provides that the amount of the credit must be applied in  
            equal amounts over the three successive taxable years  
            beginning with the taxable year in which the purchase of the  
            qualified principal residence is made. 

          5)Defines "qualified home" as a home that has never been lived  
            in before and serves as the purchaser's primary place of  
            residence. 

          6)Requires sellers of homes to provide to the taxpayer and the  
            FTB a certification that the residence has never been  
            occupied.   

          7)Disallows the credit if the taxpayer does not occupy the house  
            for at least two years immediately following the purchase of  
            the house, and requires the FTB to collect any underpayments  
            from the taxpayer. 

          8)Limits the total amount of credit to $100 million and requires  
            the FTB to allocate the credit on a first-come, first-served  
            basis, upon receipt of certification from the taxpayer. 

           FISCAL EFFECT  :   The Franchise Tax Board (FTB) staff estimates  
          that this bill will result in a revenue loss of $17 million in  
          fiscal year (FY) 2009-10, $17 million in FY 2010-11, and $14  
          million in FY 2011-12.

           COMMENTS  :   

          1)The author states that, "When legislators passed the tax  
            credit back in February, we were hopeful it would work to  








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            stimulate the state's hibernating housing market.  Then, as we  
            all know, home shoppers were sitting on the fence, refusing to  
            go back into the market.  In just two months, more than half  
            of the credits are gone.  At this pace, the credit will run  
            out early this summer, even though legislators approved the  
            program for a full year - through March 1, 2010. The tax  
            credit is doing a lot to restore confidence in California's  
            housing market.  We have been hearing from homebuilders and in  
            news reports that both traffic and sales are up dramatically  
            and we've seen a surge in permits for new construction. That's  
            why I'm pleased to be a joint author of this legislation,  
            along with Assembly Member Solorio.  This legislation is about  
            job creation and economic stimulus." 

          2)The proponents of this bill question the effectiveness of the  
            tax credit for new home purchases and tax policy of  
            subsidizing new homes instead of foreclosed or other homes on  
            the market.  The opponents argue that taxpayers are already  
            afforded generous tax benefits for homeownership.  Finally,  
            the opponents believe that the existing tax credit provides a  
            subsidy to new home developers.  

          3)Committee staff notes all of the following:

              a)   Background on the existing California tax credit for  
               purchases of new homes  .  In February 2009, the Legislature  
               enacted a new tax credit of up to $10,000 for taxpayers who  
               purchase new homes between March 1, 2009 and March 1, 2010.  
                [SBx2 15 (Ashburn), Chapter 11, Statutes of 2009-10].  As  
               of May 6th, FTB received 5,668 applications requesting  
               $54.93 million in tax credits, although FTB cautions that  
               these figures are based on claim amounts, not the amount of  
               credit applied.  FTB accepts applications only by fax, and  
               has not yet sent notifications to taxpayers of credit  
               allocations because it must first develop a system to  
               capture and verify application information, allocate  
               credits, and send letters.  Taxpayers may only claim the  
               credit after FTB allocates it.  AB 765 allows a taxpayer to  
               reserve a credit prior to close of escrow, provided that  
               the taxpayer and seller jointly sign and submit to FTB a  
               certification stating that they entered into the sale  
               agreement prior to March 1, 2010.  This measure also  
               increases the aggregate credit amount from $100 million to  
               $300 million and extends the deadline for purchases of new  
               homes until December 10, 2010.








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              b)   Federal tax credit for the first-time homebuyers .  The  
               federal tax credit for purchases of homes was originally  
               enacted by the Housing and Economic Recovery Act of 2008  
               (P.L. 110-289) and later was modified by the American  
               Recovery and Reinvestment Act of 2009.  The refundable tax  
               credit, as originally enacted, was allowed to first-time  
               homebuyers with certain adjusted gross incomes (AGI), who  
               purchase homes after April 8, 2008 and before July 1, 2009.  
                The credit phases out for single taxpayers with AGIs that  
               exceed $75,000 (or $150,000 for married couples filing  
               jointly).  The maximum amount of credit was the lesser of  
               $7,500 or 10% of the home's purchase price, but was  
               increased to $8,000 later for purchases made after December  
               1, 2008 and before December 1, 2009.  In addition, the  
               credit is no longer required to be recaptured unless the  
               taxpayer sells the qualified residence within 36 months of  
               the purchase. 

              c)   Housing market in California .  Recent data released by  
               the Commerce Department shows that new home sales,  
               nationally, fell only 0.6% to an annual rate of 356,000  
               units in March, a sign that the free fall in new home sales  
               may be over.  The California Association of Realtors' (CAR)  
               data indicates that more homes are selling and selling  
               faster, while fewer homes are coming on the market.  In  
               January 2009, CAR reported an increase in sales of 100.8%  
               for existing, single-family homes sales in January 2009  
               compared to January 2008 while the unsold inventory  
               decreased to 6.7 months from 16.6 months a year ago.  This  
               is the first time since October 2005 that the California  
               Housing Market has seen existing home sales of over 600,000  
               homes and a 14% increase over the previous month. News  
               reports also indicate that, particularly among lower-priced  
               houses in select markets, buyers are emerging, and  
               increasing foreclosures add to supply, further pushing  
               house prices down and making houses more affordable.  It  
               appears that, even with the price changes in housing  
               markets in recent years, markets again show that they work,  
               and that the best incentive for house purchasing is low  
               prices. 

              d)   Foreclosure crisis in California  .  The number of United  
               States (U.S.) households faced with losing their homes to  
               foreclosure, however, jumped 32% in April of 2009, compared  








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               with the same last year, according to RealtyTrac Inc., an  
               online foreclosure tracking firm.  Lenders filed a record  
               number of mortgage default notices against California  
               homeowners during the first three months of this year - one  
               in every 138 households received a foreclosure filing.  The  
               increase in the number of foreclosures in April is  
               attributed to the recession and lenders playing catch-up  
               after a temporary lull in foreclosure activity.  Foreclosed  
               homes represent a majority of the homes on the market.  The  
               National Association of Realtors estimates that 45% of  
               sales involve foreclosed homes, compared with roughly 10% a  
               year ago.  According to RealtyTrac Inc., nearly 70% of the  
               foreclosed homes in the firm's database have not been  
               listed for sale.  In many neighborhoods, foreclosed homes  
               are becoming a source of blight and can present safety  
               concerns for other residents. 

             Foreclosures negatively impact a community in which the  
               foreclosed property is located.  A glut of foreclosed homes  
               for sale depresses home market values for the other owners.  
                Further, neighboring businesses "often experience a direct  
               monetary loss from reduced sales and neighborhood landlords  
               experience a loss or reduction in rental income. Moreover,  
               the homes left vacant by foreclosure lower the desirability  
               of the neighborhood since there is often an increase in  
               crime associated with a vacant house." (The Subpime Lending  
               Crisis, The Economic Impact on Wealth, Property Values and  
               Tax Revenues, and How We Got Here, Report and  
               Recommendations by the Majority Staff of the Joint Economic  
               Committee, Senator C. Schumer, Chairman, Rep. C. Maloney,  
               Vice Chair, October 2007). 

              e)   Neighborhood Stabilization Program  .  As the number of  
               foreclosed properties has grown, local governments have  
               become increasingly concerned about the upkeep of abandoned  
               properties.  Banks are absentee owners and, often, are not  
               even located in the same city or state.  Even though they  
               have a financial interest in the property, they are not  
               necessarily interested in maintaining properties for the  
               sake of the community.  Last summer, Congress made  
               available to cities $6 billion for purposes of acquiring  
               and rehabilitating foreclosed properties.  The aim of the  
               federal effort is to provide funds to help states and local  
               government to deal with abandoned and foreclosed homes,  
               reduce blight, and add affordable housing.  For example,  








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               the City of Los Angeles intends to use its $33 million in  
               federal funds to turn some of the homes into low-income  
               rental housing and to refurbish others and sell to  
               low-income and moderate-income families.  Los Angeles saw  
               more than 21,000 foreclosures in 2007 and 2008, and many of  
               those homes are still on the market.  (See, e.g., W.  
               Heisel, L.A. Starts Buying Foreclosed Homes with Federal  
               Aid, LA Times, April 9, 2009).  Even if all of the $33  
               million were used to buy foreclosed homes, the city would  
               be able to purchase only a small fraction of those houses -  
               300 homes at an average price of $100,000. 

              f)   The homebuyer tax credit and economy.   Generally, many  
               economists across the political spectrum agree that a home  
               buyer tax credit or interest rate subsidies will do little  
               to stimulate the economy.  For example, with respect to the  
               federal tax credit for the first-time home buyers, critics  
               say that most of the benefits are likely to go to those who  
               would have purchased homes anyway and is unlikely to do  
               much to increase housing demand.  (Center on Budget and  
               Policy Priorities, April 11, 2008).  Others state that, as  
               a general principle, "an explicit federal subsidy for the  
               purchase of certain homes is both bad tax policy and bad  
               housing policy."  (D. C. John, The Isakson Tax Credit:  
               Another Approach that Won't Fix the Mortgage Mess, Web  
               Memo, The Heritage Foundation, March 31, 2008).  The  
               federal tax credit for first-time homebuyers is expected to  
               potentially alter "the timing of some home purchases, but  
               over the long run not [to raise] the total number of new  
               home buyers in the market."  (Gary V. Engelhardt, Economics  
               Professor, Written testimony before the House Small  
               Business Committee, June 5, 2008).  Finally, some  
               commentators called the federal tax credit "an implicit  
               subsidy to homebuilders" that "would keep home prices  
               artificially high when they probably ought to be falling."   
               (Tomasz Piskorski, Assistant Professor of Finance and  
               Economics, Columbia Business school, BusinessWeek Online,  
               June 6, 2008). 

             Proponents of the federal tax credit point to similarly  
               structured subsidies that Congress approved in 1975, giving  
               qualified buyers a 5% credit and bringing down the interest  
               rates to 7%.  Critics, however, argue that the analogy is  
               misleading because the U.S. was exiting a recession that  
               had been induced by oil prices, not a slide in home values.  








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                (N. Timiraos, Economics Skeptical of Home Buyer Tax Credit  
               and Other Incentives, Wall Street Journal, Developments).  

              g)   How effective is the California homebuyer tax credit  ?   
               The proponents argue that, because of the original tax  
               credit enacted in February of 2009, home builders in  
               California have seen increased sales, have started  
               construction of new homes, and have hired new employees.   
               Furthermore, the cancellation rates on sales of new homes  
               have fallen to 13%, in contrast to the 50% averages months  
               ago.  According to a study done by the Sacramento Regional  
               Research Institute, the California construction industry  
               contributes $40 billion per year to the state's economy and  
               is responsible for 266,000 jobs statewide.  The entire  
               housing industry accounts for 11% of all economic activity  
               in California.  Every dollar spent on new housing  
               construction in California generates 90 cents in total  
               economic activity, while each job created through  
               residential construction supports an additional job.  (The  
               Economic Benefits of Housing in California, A report  
               prepared by the Sacramento Regional Research Institute and  
               sponsored by California Homebuilding Foundation, August  
               2008).  

             Despite the industry's enthusiasm, some economists say "the  
               credit is doing little to fix what truly ails California --  
               one of the nation's largest residential markets -- because  
               it doesn't encourage the sale of foreclosed houses that are  
               weighing on prices."  (M. Corkery, Tax Credit Gives  
               California Builders a Lift, Wall Street Journal, April 24,  
               2009).  Indeed, some economists warn that if the tax credit  
               is extended, it could negatively affect the sale of  
               existing homes and the housing market overall.  For  
               example, Christopher Thornberg, principal at Beacon  
               Economics, a Los Angeles-based research firm, argues that  
               "California has thousands of foreclosed homes that need to  
               be sold" and that the building of new homes should not be  
               promoted. (Id.).  Similarly, Alan J. Auerbach, Director of  
               the Burch Center for Tax Policy and Public Finance at the  
               University of California, Berkley, cited the recently  
               adopted tax credit as an example of the pitfalls of  
               targeted tax cuts.  He stated that, by providing an  
               incentive for the purchase of new homes, "this credit will  
               encourage additional construction, which is probably the  
               last thing we should be doing right now" and "will  








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               discourage the purchase of existing, previously occupied  
               homes, thereby adding to the capital loses that homeowners  
               have already suffered."  (A. Auerbach, California's Tax  
               System in Crisis and Beyond,  A testimony before the  
               Committee on Revenue and Taxation, California Assembly,  
               March 23, 2009).   

              h)   Should the existing tax credit be expanded  ?  Even though  
               it appears that the California tax credit for the purchase  
               of new homes has created jobs in the construction industry  
               and encouraged new construction, the question still remains  
               as to whether the extension of the credit is warranted.   
               First, this bill provides a subsidy only to a specific  
               group of taxpayers - buyers of new homes and, ultimately,  
               homebuilders.  Clearly, a construction industry is very  
               important to the state's economy.  The decline in new home  
               construction has resulted in the loss of $46 billion in  
               economic output for California from 2005 to 2009, and more  
               than 300,000 jobs were lost in housing and its related  
               sectors.  However, one could argue that the high-tech and  
               manufacturing industries are equally important and  
               struggling manufacturing companies that are laying off  
               their workers could equally benefit from a tax credit or  
               another form of subsidy.  

             Furthermore, should homebuilders get assistance in selling  
               houses that, arguably, should not have been built in the  
               first place?  Does California need more new houses at this  
               point, especially in light of the fact that 16 brand new  
               homes in a small housing development in San Bernardino  
               County were demolished just a few weeks ago?  It was  
               reported that Guaranty Bank of Austin acquired those homes  
               in foreclosure and is destroying them in Victorville City,  
               about 85 miles northeast of Los Angeles, rather than paying  
               daily fines to the City of Victorville for failure to  
               maintain the property. (P. Hong, Housing Crunch Becomes  
               Literal in Victorville, Los Angeles Times, May 5, 2009).   
               According to the LA Times article, nearly 250 residential  
               developments totaling 9, 389 homes have been halted across  
               the state.

             In addition, as the number of foreclosed properties has  
               grown, local governments have become increasingly concerned  
               about the upkeep of abandoned properties. The Committee may  
               wish to consider whether AB 765, by providing an incentive  








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               to buy new homes, would undermine the efforts of local  
               governments to sell foreclosed properties. 

             Further, at the time of a severe fiscal stress, the costs of  
               existing tax incentives already available to homeowners  
               should be considered in deciding whether a $10,000 subsidy  
               for the purchase of a new home is justified.  For example,  
               taxpayers may deduct interest payments on up to $500,000  
               single/$1 million joint of indebtedness used to purchase a  
               first and second home.  Taxpayers may also deduct interest  
               payments on up to $100,000 in home improvement loans.  The  
               Department of Finance (DOF) estimates that this tax benefit  
               results in more than $5.4 billion in foregone revenue in  
               fiscal year (FY) 2009-10.  In addition, taxpayers may  
               exclude up to $250,000 single/$500,000 joint in income  
               resulting from the sale of their principal residence.  The  
               DOF estimates that this tax benefit results in more than  
               $3.7 billion in foregone revenue in FY 2009-10.  Finally,  
               taxpayers who purchase a house in 2009 may be entitled to  
               both the federal and state home purchase tax credits.  

             Finally, a glut of housing, which is expressed in the numbers  
               of foreclosed homes, is one of the most pressing problems  
               the economy is facing now.  More new homes translate into  
               higher housing inventories and lower prices of existing  
               homes.  It would take California's economy longer to come  
               out of recession.  The Committee may wish to consider those  
               additional costs while discussing the benefits of  
               encouraging the construction of additional housing.  The  
               Committee may also wish to examine the rationale for giving  
               a huge subsidy only to people who buy new homes and not  
               renters, and to consider whether the extension of the  
               homebuyer credit will produce sufficient gain to the  
               general public to justify its costs.  

              i)   Implementation concerns  .  The FTB staff identified a  
               number of implementation concerns, which need to be  
               resolved if this bill moves out of this committee.  It is  
               the Committee staff's understanding that the author is  
               working with FTB staff to address those concerns. 

              j)   Related Legislation.

              SB 49 (Dutton), introduced in the current legislative  
               session, is almost identical to this bill.  SB 49 was heard  
                                         







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               in the Senate Revenue and Taxation Committee on May 13,  
               2009 and was placed on the committee's suspense file. 

             AB 902 (Torres), introduced in the current legislative  
               session, would allow a maximum credit of $3,000 for the  
               purchase of a foreclosed property that would be used as the  
               taxpayer's primary residence.  AB 902 is pending in this  
               Committee. 

             SBx2 15 (Ashburn), Chapter 11, Statutes of 2009-10, enacted a  
               homebuyer tax credit for the purchase of qualified  
               principal residence.  

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          None on file

           Opposition 
           
          California Tax Reform Association
           
          Analysis Prepared by  :  Oksana Jaffe / REV. & TAX. / (916)  
          319-2098