BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1836
                                                                  Page  1

          Date of Hearing:  May 10, 2010

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                            Anthony J. Portantino, Chair

                   AB 1836 (Furutani) - As Amended:  April 5, 2010


                                      VOTE ONLY


          2/3 vote.  Tax levy.  Fiscal committee.

           SUBJECT  :  Personal Income Tax:  10% and 11% brackets

           SUMMARY  :  Temporarily establishes 10% and 11% personal income  
          tax (PIT) brackets for high-income taxpayers and increases the  
          alternative minimum tax (AMT) rate to 8.5%.  Specifically,  this  
          bill :  

          1)Establishes a 10% PIT rate for the following:

             a)   Single filers whose taxable income is over $250,000 and  
               equal to or less than $400,000;

             b)   Joint filers whose taxable income is over $500,000 and  
               equal to or less than $800,000; and, 

             c)   Head of household filers whose taxable income is over  
               $400,000 and equal to or less than $600,000. 

          2)Establishes an 11% PIT rate for the following:

             a)   Single filers whose taxable income is over $400,000;

             b)   Joint filers whose taxable income is over $800,000; and,  


             c)   Head of household filers whose taxable income is over  
               $600,000; 

          3)Increases the AMT rate to 8.5%.  

          4)Is operative for taxable years beginning on or after January  
            1, 2011, and before January 1, 2016.  








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           EXISTING FEDERAL LAW  :

          1)Imposes six different income tax rates on individuals,  
            estates, and trusts ranging from 10% to 35%.

          2)Provides an AMT rate of 26% on AMT income up to $175,000 and  
            28% on AMT income exceeding that amount.  
           EXISTING STATE LAW  :

          1)Imposes, for taxable years beginning on or after January 1,  
            2009, and before January 1, 2011, six different PIT rates  
            ranging from 1.25% to 9.55%.  Each rate applies to a different  
            range of income, known as a "tax bracket."  The Franchise Tax  
            Board (FTB) is required to recalculate the tax brackets each  
            year based on the change in the California Consumer Price  
            Index.  

          2)Imposes an addition 1% Mental Health Tax, not subject to  
            reduction by credits, on the portion of a PIT taxpayer's  
            taxable income that exceeds $1 million.  

          3)Provides an AMT rate of 7.25% for taxable years beginning on  
            or after January 1, 2009, and before January 1, 2011.  

           FISCAL EFFECT  :  FTB estimates that this bill would increase  
          General Fund revenues by $1.1 billion in fiscal year (FY)  
          2010-11, by $2.1 billion in FY 2011-12, and by $2.4 billion in  
          FY 2012-13.  

           COMMENTS  :   

           1)Author's Statement.   The author has provided the following  
            statement in support of this bill:

               In 1991, California was entering a deep recession, and the  
               unemployment rate was increasing.  The State's budget  
               deficit grew as the months passed.  The Legislative  
               Analyst's Office (LAO) wrote at the time, "[u]nderlying  
               structural budget problems and the onset of a national  
               recession have combined to pose extremely difficult  
               challenges for the 1991-92 state budget."

               When then-Governor Wilson unveiled his May Revision in  
               1991, the updated budget plan was based on a deficit of  








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               $14.3 billion.  In order to bridge the gap, the 1991-92  
               budget Governor Wilson signed into law included $3.4  
               billion in expenditure reductions and $9.1 billion in  
               increased resources.  Notably, the increased resources that  
               Governor Wilson relied on included $5.1 billion in  
               state-level tax increases.

               AB 1836 is a less restrictive version of the temporary tax  
               brackets initiated by former Governor Wilson in 1991.  If  
               in place today, Governor Wilson's tax brackets would apply  
               to single filers with taxable income over $163,954 and  
               joint filers with taxable income over $327,913.  Like the  
               tax brackets established by Governor Wilson, the tax  
               brackets under AB 1836 are temporary and apply only to tax  
               years 2011-15.  If passed, AB 1836 is estimated to raise  
               almost $14 billion of critical funding over the next five  
               years.  AB 1836 will only affect the wealthiest of  
               Californians and not low-income or middle class individuals  
               and families that have been hit hard by the recession and  
               the Governor's past budget cuts.

           2)Argument in Favor.   Proponents of this bill state that low and  
            middle income Californians have already been hit hard by the  
            economic downturn.  Over the last two years, over $2 billion  
            has been cut from health and human services programs meant to  
            help keep families afloat during tough economic times.   
            Governor Schwarzenegger has proposed cutting another $6.4  
            billion from health and human services to close the budget  
            gap, without proposing real revenue-raising budget solutions.   
            Health care has already been cut to the bare bones and the  
            state's budget woes cannot be solved on the backs of  
            California's lowest-income families.  Enrollment for CalWORKS,  
            Medi-Cal, and Healthy Families has increased despite budget  
            cuts.  This problem cannot be fixed by continuing to cut  
            programs.

           3)Argument in Opposition.   Opponents of this bill state that  
            California just recently increased all its income tax brackets  
            by .25%, giving it the highest rates in the country.   
            California already has the most progressive income tax  
            structure in the United States, with the top 1% of earners  
            paying half the tax revenue California receives.  If anything,  
            California needs fewer tax brackets to keep it from becoming  
            over-reliant on one source of revenue.  This measure will only  
            add credence to the notion that California is the most taxed  








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            state in the union.

           4)Background.   Throughout California's history, governors and  
            the Legislature have imposed progressive tax brackets on the  
            highest income earners.  Beginning with Governor Ronald  
            Reagan, a 10% tax bracket was enacted in 1967, and later  
            raised to 11% in 1971.  In the early 1990's, California faced  
            a severe recession, which resulted in significant shortfalls  
            in the state budget.  In response, the State acted to increase  
            revenues and reduce expenditures.  The Legislature and  
            Governor Pete Wilson, in addressing the issue, increased the  
            PIT rates by adding a 10% and an 11% tax bracket for the  
            State's highest income earners.  In 1991, the 10% rate was  
            imposed on filers with incomes over $100,000 (single) and  
            $200,000 (married filing jointly).  The 11% rate was imposed  
            on filers with taxable incomes over $200,000 (single) and  
            $400,000 (married filing jointly).  These income thresholds  
            were increased for inflation each year, so that by 1995, the  
            10% rate was imposed on filers with taxable incomes over  
            $109,936 (single) and $219,872 (married filing jointly), and  
            the 11% rate was imposed on filers with taxable incomes over  
            $219,872 (single) and $439,744 (married filing jointly).
           
             In 1995, supporters of a permanent extension of the tax  
            bracket rates placed Proposition 217 on the ballot.  The  
            measure would have continued the 10% and 11% tax rates  
            permanently and allocated revenue from the increase to schools  
            and local governments.  Proposition 217 failed narrowly by  
            2/10 of one percentage point.

           5)Committee Staff Comments:

             a)   Progressive Taxation.   California currently has a  
               progressive taxation system.  A progressive tax is one  
               where the tax rate increases as the taxable base amount  
               increases.  As explained earlier, California has six  
               different tax rates, each increasing as the base increases.  
                There are several schools of thought addressing this  
               issue.  Generally speaking, there are those who believe in  
               a progressive system of taxation, and those who do not,  
               preferring other methods of taxation, like a flat tax.
            
               The argument against a progressive tax system is similar to  
               the one espoused by Austrian economist and author, Eugen  
               Von Bohm-Bawerk.  Addressing the concept in his work, Karl  








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               Marx and the Close of his System, Von Bohm-Bawerk focuses  
               his argument on the consumption of goods versus the  
               consumption of capital.  Applying the concept of  
               diminishing returns, as income rises, a smaller portion of  
               that income will be used for consumption of goods.  By  
               default, a larger portion will be used for capital  
               investments, which will generate more income for more  
               capital investments.  By purchasing more and more capital  
               goods, the cost of production begins to fall and begins to  
               elevate the standard of living.  A progressive system of  
               taxation would increase the tax rate on higher income  
               individuals, reducing the amount of income available for  
               capital investments and thereby reducing improvements to  
               the standard of living.  

               This argument against a progressive system of taxation,  
               however, fails to address the issue of a growing gap  
               between those who have capital investments generating an  
               exceedingly greater amount of income and those who are just  
               able to pay for life's necessities.  Because low income  
               earners spend a larger share of their income on  
               necessities, they have a much smaller portion of income  
               left over to make their own capital investments.  The  
               argument also fails to address the elimination of jobs from  
               increased capital improvements.  For example, a company  
               employing 10 workers may decide to purchase large capital  
               equipment, eliminating the need for those workers.  The  
               machine can perform the same amount of work, but the  
               business will become more efficient by reducing its labor  
               costs in subsequent years.

               The idea of a progressive tax system has gained acceptance  
               from a wide range of individuals.  Writing in The Wealth of  
               Nations, Adam Smith outlined the hardship and burden that  
               lower income individuals have in society.  Specifically,  
               Smith focused on the necessities of life, which low income  
               individuals spend a much larger percentage of their income  
               on.  In recognizing the disproportionate impact on the  
               poor, Smith stated, "it is not very unreasonable that the  
               rich should contribute to the public expense, not only in  
               proportion to their revenue, but something more than in  
               that proportion."  Other arguments also encourage the use  
               of a progressive taxation system because individuals with  
               greater capital are also more likely to take advantage of  
               societal benefits supported by taxation, such as defense,  








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               infrastructure, and the protection of property rights.   
               Individuals who control larger sums of capital are also  
               able to take advantage of economies of scale, a wider range  
               of investment opportunities, and are able to more directly  
               participate in shaping government.  By providing a  
               progressive tax system, democracies are better able to  
               enhance economic opportunity for the lower and middle  
               classes.  

              b)   Revenue Volatility.   Revenue volatility is related to  
               both California's economic cycle and its tax structure.  As  
               noted in Revenue Volatility in California by the  
               Legislative Analyst's Office (LAO), California's economic  
               cycle has historically been more volatile than the nation's  
               economic cycle due to the presence of high-paying cyclical  
               technology-related industries and the housing sector.  In  
               addition to the historic volatility of California's  
               economic cycle, revenue volatility has also been an issue  
               because of California's increased dependency on the PIT.    
               The percentage of state revenue coming from the PIT has  
               increased from 37% in 1979-80 to a peak of 57% in 2000-01.   
                

                LAO's report mentioned several ways in which California  
               could reduce the volatility of its revenues.  Among them  
               was reducing the progressivity of the basic PIT structure.   
               This would involve flattening the PIT structure by  
               increasing the tax rates on lower and moderate income  
               earners and reducing the tax rate on high-income earners.   
               Other suggestions included increasing the State's reliance  
               on alternative tax revenues.  Specifically, the State may  
               be able to reduce its dependence on the PIT by extending  
               taxes to services, which tend to be relatively stable  
               during a business cycle, or by increasing property taxes.  

               With regard to property tax, revenues generated from the  
               levying of taxes on property tend to be the most stable of  
               the major state and local sources.  According to the  
               Commission on the 21st Century Economy, property taxes are  
               more stable because property tends not to fluctuate as much  
               as other tax bases in response to the business cycle, most  
               notably the PIT.  Prior to 1978, property tax was assessed  
               at the market value.  In 1978 voters passed Proposition 13,  
               which limited assessments to the property's acquisition  
               value, plus an annual increase capped at the lesser of 2%  








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               or the rate of inflation.  Proposition 13 also added a  
               two-thirds vote requirement for raising taxes.  After the  
               passage of Proposition 13, there was a dramatic drop in  
               property taxes relative to personal income.  Property tax  
               as a share of personal income dropped from 5% in years  
               1977-78 to 2.4% in years 2005-06.  In terms of preventing  
               volatility in the state's revenue, Proposition 13 made it  
               incredibly difficult to raise revenue from one of the most  
               stable sources.  Of course, it is also important to note  
               that volatility is only a problem if state government  
               operates with an expectation of stability.  If the  
               Legislature properly addresses the issue of volatility  
               within the budget, state funded programs and other costs  
               could be properly managed without having to restructure  
               California's tax system.  

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          American Federation of State, County and Municipal Employees,  
          AFL-CIO
          Asian Americans for Civil Rights & Equity
          California Commission on the Status of Women
          California Immigrant Policy Center
          California Labor Federation
          California Professional Firefighters
          California School Employees Association 
          California Tax Reform Association
          California Teachers Association
          Coalition for Humane Immigrant Rights of Los Angeles
          Health Access Coalition
          Jericho
          Lutheran Office of Public Policy - California
          National Association of Social Workers
          Planned Parenthood Affiliates of California 
          Services, Immigration Rights & Education Network

           Opposition 
           
          California Aerospace Technology Association
          California Bankers Association
          California Chamber of Commerce
          California Manufacturers & Technology Association of America
          California Taxpayers' Association








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          Howard Jarvis Taxpayers Association
           
          Analysis Prepared by  :  Carlos Anguiano / M. David Ruff / REV. &  
          TAX. / (916) 319-2098