BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1508
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          Date of Hearing:   April 29, 2009

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                   AB 1508 (Torrico) - As Amended:  April 16, 2009
           
           [This bill has been double referred to the Assembly Committee on  
          Revenue and Taxation and will be heard as it relates to the  
          issues under its jurisdiction.]
           
          SUBJECT  :   Income and corporation taxes: credit: lending  
          employees to schools.

           SUMMARY :   Establishes a tax credit, beginning January 1, 2010,  
          for corporations that lend qualified employees, as defined, to  
          Title I public high schools to assist in teaching mathematics or  
          science and that also make charitable donations including, but  
          not limited to, classroom materials, resources, equipment, and  
          facilities.   Specifically,  this bill  :  

          1)Requires for each taxable year beginning on or after January  
            1, 2010, there to be allowed as a credit against the "net  
            tax," as defined in Section 17039, and the "tax" as defined in  
            Section 23036, an amount equal to ___ percent of the amount  
            paid or incurred during the taxable year for qualified  
            expenses in connection with lending a qualified employee to a  
            Title I public school for the purpose of assisting in the  
            teaching of mathematics and science.

          2)Defines "Qualified expenses"  to mean both of the following:
             a)   Amounts paid or incurred by the taxpayer with respect to  
               expenses incurred by or on behalf of a taxpayer's employee  
               for the amount of compensated hours utilized for lending a  
               qualified employee to a Title I public school for the  
               purpose of assisting in the teaching of mathematics and  
               science.
             b)   Expenses paid or incurred by the taxpayer for the wages  
               of a qualified employee, to the extent those wages are  
               allocable to teaching.

          3)Defines "Title I public school" to mean any high school in  
            this state that is a part of a public school district in which  
            at least 40% of the children in the school attendance area are  
            from low-income families or at least 40% of the students  
            enrolled are from low-income families eligible to receive  








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            federal Title I funds.

          4)Defines "Mathematics" to mean instruction designed to develop  
            fluency in basic computational skills and an understanding of  
            mathematical concepts and mathematical reasoning and problem  
            solving, including, but not limited to, number sense,  
            algebraic functions, geometry and other measurement functions,  
            statistics, data analysis, probability analysis, and  
            quantitative concepts; and, specifies "Mathematics" includes,  
            but is not limited to, courses in algebra I, algebra II,  
            linear algebra, calculus, geometry, trigonometry, mathematical  
            analysis, probability and statistics, and advanced probability  
            and statistics.

          5)Defines "Science" to mean instruction designed to develop  
            skills and procedures for the systematic pursuit of knowledge  
            that includes, but is not limited to, problem solving and  
            recognition, the collection of data through observation and  
            experiment, and the formulation and testing of hypotheses;  
            and, specifies "Science" includes, but is not limited to,  
            courses in biology, life science, physical science, physics,  
            chemistry, geoscience, health science, and computer science.

          6)Specifies a credit shall be allowed under this section only if  
            a Title I public school issues a service record to the  
            taxpayer certifying receipt of the services; and, specifies  
            that service record shall contain the employee's name, dates  
            of teaching service, number of teaching hours, verification of  
            the employee's eminence credential, or eligibility for the  
            issuance thereof, and a verification signature from an  
            authorized agent or designee of the high school.

          7)Specifies no deduction shall be allowed to a taxpayer for that  
            amount of expenses for which a credit is allowed to that  
            taxpayer under this section.

          8)Specifies no credit shall be allowed under this section with  
            respect to the lending of a qualified employee to a high  
            school unless both of the following apply:
             a)   The employee does not supplant, or otherwise replace,  
               any teacher at the school. 
             b)   The taxpayer makes charitable donations including, but  
               not limited to, classroom materials, resources, equipment,  
               and facilities.









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          9)Specifies the maximum amount allowable as a credit to the  
            taxpayer shall be based on ___ percent of the total amount of  
            charitable contributions to the school for that taxable year;  
            and, specifies in the case where the credit allowed by this  
            section exceeds the "net tax" or "tax" the excess may be  
            carried over to reduce the "net tax" or "tax" in the following  
            year, and the succeeding seven years if necessary, until the  
            credit is exhausted.

          10)Specifies this act provides for a tax levy within the meaning  
            of Article IV of the Constitution and shall go into immediate  
            effect.

           EXISTING LAW  : 

          1)Authorizes, upon the recommendation of the governing board of  
            a school district, the Commission on Teacher Credentialing to  
            issue an eminence credential to any person who has achieved  
            eminence, recognized outside their community, in a field of  
            endeavor taught or service practiced in the public schools of  
            California.  This credential shall authorize teaching or the  
            performance of services in the public schools in the subject  
            or subject area or service and at the level or levels approved  
            by the commission as designated on the credential.  Each  
            credential so issued shall be issued initially for a two-year  
            period and may be renewed for a three-year period by the  
            commission upon the request of the governing board of the  
            school district.  Upon completion of the three-year renewal  
            period, the holder of an eminence credential shall be eligible  
            upon application for a professional clear teaching credential.  


          2)Provides various credits to businesses in order to provide  
            incentives for them to perform various actions or activities.   
            Credits have been provided to offset employer cost of  
            subsidizing employee ridesharing programs and transit passes,  
            and employer cost of providing various child care facilities  
            and services.

          3)Provides various deductions for ordinary and necessary  
            business expenses of trade or business, such as, salaries,  
            wages, and employee benefits.  Employers are also eligible to  
            claim charitable contribution deductions.

           FISCAL EFFECT  :   Unknown








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           COMMENTS  :  This bill would allow a credit on personal income tax  
          or corporation tax equal to ___% of the taxpayer's expenses  
          associated with loaning the taxpayer's employees to Title I  
          public high schools for the purpose of assisting in teaching  
          mathematics or science.  Qualified expenses would include  
          employee wages allocable to teaching or employee expenses  
          related to teaching.  Eligible employees are those whose  
          employment specialty includes math or science.  The credit would  
          only be allowed for employees loaned to Title I public high  
          schools if the employee has, or is eligible for, an eminence  
          credential.  The credit would only be allowed for employees  
          loaned if the taxpayer also makes charitable donations of  
          classroom materials, resources, equipment and facilities; and,  
          the maximum amount of tax credit shall be equal to a certain  
          percentage of the amount of charitable donations made to the  
          school that taxable year.   No deduction would be permitted for  
          expenses for which the credit is claimed.  If the credit exceeds  
          the taxpayer's tax liability (e.g., if the taxpayer is in a loss  
          position and pays no tax for the year), the credit may be  
          carried forward to up to 7 future years.
           
          Committee Considerations  .  The bill specifies that a certain  
          percentage of "qualified expenses" shall be granted as a tax  
          credit for employers, but in a different section the bill also  
          specifies that a tax credit shall be based on a certain  
          percentage of "the total amount of charitable contributions to  
          the school for that taxable year."  The author's intent is to  
          have the amount of the tax credit for "qualified expenses" be  
          limited by the amount of charitable donations given to the  
          school by the taxpayer during the taxable year.  The committee  
          should consider clarifying the language in the bill regarding  
          the maximum tax credit allowed.  

          The definition of "qualified expenses" includes the wages and  
          expenses incurred by the visiting teacher.  It is unclear if  
          "expenses" would include costs associated with commuting  
          including meals and mileage or if the intent is to include  
          expenses such as supplies needed for the lesson, etc.  The  
          committee should consider whether the definition of "qualified  
          expenses" could be further clarified.

          The bill authorizes employers to receive a tax credit for  
          expenses incurred by the employee associated with teaching.  The  
          committee should consider that existing teachers cannot deduct  








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          expenses for commuting.  Further, only in certain, limited  
          circumstances may teachers deduct expenses for teaching  
          supplies, class materials and equipment.  The committee should  
          consider whether this bill creates an inequity to allow an  
          employer to receive a tax credit for such expenses, when a  
          regular teacher is not eligible for the same type of credit.
           
          Title I Schools  .  Title I is part of the Elementary and  
          Secondary Education Act of 1965, and is the foundation of the  
          federal commitment to closing the achievement gap between  
          low-income and other students.  Title I funds can be used for  
          instructional activities, counseling, parental involvement, and  
          program improvement.  In return, school districts and states  
          must meet accountability requirements for raising student  
          performance.  Local educational agencies target the Title I  
          funds they receive to schools with the highest percentages of  
          children from low-income families.  Unless a participating  
          school is operating a schoolwide program, the school must focus  
          Title I services on children who are failing, or most at risk of  
          failing, to meet state academic standards.  Schools in which low  
          income children make up at least 40% of enrollment are eligible  
          to use Title I funds for schoolwide programs that serve all  
          children in the school.  

          Eminence Credential  .  The Commission on Teacher Credentialing  
          (CTC) is authorized to grant an Eminence Credential to an  
          individual who is eminent in a specific endeavor and is  
          recognized as such beyond the boundaries of his or her  
          community, has demonstrably advanced his or her field and has  
          been acknowledged by his or her peers beyond the norm for others  
          in the specific endeavor.  Eminence credentials are only  
          available at the recommendation of an employing agency.  The  
          employing agency must demonstrate how the eminent individual  
          will enrich the educational quality of the employing agency.   
          The bill specifies the school must provide a certifying receipt  
          documenting the service record of the employee including the  
          verification of the employee's eminence credential, or  
          eligibility for the issuance thereof.  How would an individual  
          school determine a person's eligibility of an eminence  
          credential, without a credential actually being issued by the  
          CTC?  School districts, not individual schools, must make a  
          recommendation to the CTC for the issuance of an eminence  
          credential, and the ultimate authority to issue such a  
          credential is given to the CTC, not a school or district.  The  
          committee should consider how this would be implemented, and  








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          whether "eligibility" should be considered, or whether issuance  
          of the credential should instead be required.  The committee  
          should also consider that if the visiting instructor is working  
          in a classroom with a certificated teacher, an eminence  
          credential may not be necessary at all.

           Loss to the State General Fund  .  In this difficult economic  
          time, is it wise to issue tax credits to corporations, thus  
          reducing the overall state General Fund balance that would  
          otherwise go toward programs like education?   While the tax  
          credit proposed in this measure is linked to the important  
          issues of math and science education opportunities for students,  
          is this the right economic time for the state to offer such a  
          tax credit?

           Why Science and Math  ?  While there is a demonstrated shortage of  
          qualified math and science teachers in California, why should we  
          limit a tax credit only to companies in math and science fields?  
           A well-balanced student should learn history, English and other  
          languages, writing skills, art, music and literature.  One could  
          argue that great literary artists would be equally beneficial in  
          the classroom and publishing companies could equally benefit  
          from a tax credit.  The committee should consider whether it is  
          important to provide a tax credit only to companies in math and  
          science fields or if other fields would be equally important.
           
           Employer gains by loaning employees, even without a credit  .   
          High tech companies often find it very difficult to retain  
          qualified technical personnel.  For that reason, employers are  
          hesitant to lay employees off, even when times are tough.  This  
          bill effectively subsidizes employers wishing to retain  
          technical personnel rather than lay them off.  During better  
          economic times, when sales are brisk and manufacturing and  
          research deadlines are tight, it is very unlikely that any  
          business would be interested in loaning employees to assist in  
          the teaching of math and science.  Furthermore, the employer  
          gains in the long run by assisting schools in teaching math and  
          science.  It increases the pool of math- and science-educated  
          students from which the employer will eventually hire future  
          employees.  It could also be expected that loaned employees will  
          serve as ambassadors, or even recruiters, for the employer.

           The Careers Project  .  A study completed in January 2009 by the  
          California Research Bureau titled, The Careers Project, surveyed  
          businesses regarding their existing partnerships with schools.   








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          Of those businesses that indicated they did not have  
          partnerships established with schools, 56% sited that "firms do  
          not have the resources to dedicate staff to supervise or mentor  
          students;" and, 33% sited "resource issues" as the barriers to  
          establishing a partnership with middle and high schools.  The  
          Careers Project proposed the following as one of the policy  
          options for consideration, "To encourage businesses that do not  
          have the capacity to establish school-business partnerships, the  
          Legislature may consider creating a tax incentive for employers  
          to subsidize dedicated staff time for outreach activities and  
          partnerships with public middle and high schools in the state.   
          This would be particularly useful for the large majority of  
          employers in the state that are small business (i.e., less than  
          five employees).  Given our current state budget challenges,  
          such an option would further impact state revenues, so it would  
          doubtlessly need to be part of a broader discussion about the  
          priorities and goals in public education."  With this  
          recommendation in mind, the committee should consider if the  
          proposed tax credit in this measure is part of a broader  
          discussion about the priorities and goals in public education.
          
          According to the author, as one of the leaders in the "new  
          economy," more than half of California's jobs require education  
          and training beyond the high school level and are projected to  
          be higher in the next ten years.  This is also recognized by  
          California business and industry leaders as noted by the  
          California Business Roundtable:  "The shortage of qualified  
          employees is the most significant cost driver for California  
          businesses.  The business community understands that education  
          is the key to building a prosperous California.  That explains  
          why California's business leaders cited improving the quality of  
          K-12 public education as an important policy priority for  
          California's future growth."

          According to the author, unfortunately, California is seriously  
          ill-equipped to meet these workforce demands.  California's  
          students remain far behind those in other states on many  
          measures of achievement and are dropping out of school in  
          astonishing numbers.  For example, California ranked seventh  
          from the bottom in eighth grade math and second from the bottom  
          in science on the 2005 National Assessment of Education  
          Progress.  Additionally, about one-quarter of all California  
          students who enter the ninth grade fail to earn a diploma four  
          years later.  As a result, California sustains $46.4 billion in  
          total economic losses from every 120,000 20-year-olds who never  








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          complete high school.  Furthermore, more than two-thirds of all  
          high school drop outs use food stamps during their working life  
          and are 68% more likely to be on a welfare program.  AB 1508  
          will provide a tax incentive to industry leaders who provide  
          charitable contributions of resources and time to Title 1  
          schools to assist in the education of math and science.  

           Committee Amendments  :  The author indicates intent to insert the  
          amount of credit allowed under this measure.  If the bill is  
          passed by the committee, staff recommends the bill be amended to  
          include a reasonable percentage.  Staff recommends the bill be  
          amended to clarify the definition of "qualified expenses" and  
          the maximum tax credit allowed, and clarify other technical  
          language.  Staff recommends the bill eliminate the requirement  
          that qualified employees must obtain an eminence credential from  
          the CTC, but that the school district governing board must  
          certify that the person is qualified to assist in the teaching  
          of math and science.  Staff also recommends the bill be amended  
          to include an evaluation of the proposed tax credit due to the  
          Legislature by November 1, 2012; include a sunset date of  
          December 31, 2013; and, a repeal date of January 1, 2014.   

           Previous legislation  .  AB 902 (Alquist) from 2001 authorized a  
          nonrefundable tax credit to employers who lend a qualified  
          employee to a public middle or high school (i.e., grades 7  
          through 12) in California or a community college in California  
          to teach math or science.  The bill was passed by the Assembly  
          Revenue and Taxation Committee and the Assembly Floor and was  
          later substantially amended into another committee jurisdiction.  
           

          SB 558 (Morrow) from 2001 is substantially similar to AB 1508  
          (Torrico).  SB 558 would have established a credit against  
          personal income or corporation tax equal to 50% of the  
          taxpayer's expenses associated with loaning the taxpayer's  
          employees to public high schools, community colleges, or  
          vocational schools for the purpose of teaching mathematics or  
          science.  Qualified expenses would include employee wages  
          allocable to teaching or preparation time, teaching supplies,  
          class materials; and, equipment.  The credit would only be  
          allowed for employees loaned to high schools if (1) the employee  
          has, or is eligible for, an "eminence credential"; and (2) the  
          employee fills a vacancy for which no certified high school  
          teacher is available.  If the credit exceeds the taxpayer's tax  
          liability, the credit may be carried forward to up to 7 years.   








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          The credit would apply for the 2002 through 2006 tax years,  
          after which it would sunset.  The Franchise Tax Board estimated  
          a revenue loss of about $1 million annually from SB 558.  The  
          estimate was based on the assumption that loaned math and  
          science employee/teachers would comprise 1% of the total number  
          of math and science teachers in public high schools and  
          community colleges.  The bill failed passage in the Senate  
          Revenue and Taxation Committee.

          AB 462 (Wyland & Zettel) from 2001 authorized a credit against  
          those taxes for each taxable year beginning on or after January  
          1, 2002, and before January 1, 2006, in an amount equal to 50%  
          of the amount paid or incurred during the taxable or income year  
          for qualified expenses, as defined, in connection with lending  
          qualified employees, as defined, to public high schools, or  
          community colleges, in California for the purpose of teaching  
          math or science.  The bill was referred to the Assembly Revenue  
          and Taxation Committee but was never heard.

          SB 1948 (Lewis) from 2000 would have granted a 50% credit for  
          employees who lend their employees to public high schools,  
          community colleges, or vocational institutions in California for  
          the purpose of teaching mathematics or science during the 2001  
          through 2004 tax years. The credit would equal 50% of the costs  
          incurred by the employer in loaning its employees.  Loaned  
          employees could only be used to fill empty mathematics or  
          science teaching positions where no certified teacher is  
          available, must have mathematics or science as their employment  
          specialty, must be certified by the receiving school as to the  
          number of hours they work for the school, and must have been  
          issued or be eligible for an "eminence credential" pursuant to  
          Section 44264 of the Education Code.  The bill was heard by the  
          Senate Revenue and Taxation committee but no action was taken.

          AB 81 (Cuneen & Alquist) from 2000 would have offered three  
          types of incentives to increase the number of qualified math and  
          science teachers and the quality of math and science instruction  
                   in public high schools, community colleges, and vocational  
          institutions in California.  One such incentive was nearly  
          identical to that which is proposed by AB 1508 (Torrico).  The  
          bill failed passage in the Assembly Revenue and Taxation  
          Committee.

           REGISTERED SUPPORT / OPPOSITION  :   









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           Support 
           
          None on file.

           Opposition 
           
          None on file.
           

          Analysis Prepared by  :    Chelsea Kelley / ED. / (916) 319-2087