BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                  SB 1391|
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                                 THIRD READING


          Bill No:  SB 1391
          Author:   Yee (D)
          Amended:  5/19/10
          Vote:     21

           
           SENATE REVENUE & TAXATION COMMITTEE  :  3-1, 5/12/10
          AYES:  Wolk, Alquist, Padilla
          NOES:  Ashburn
          NO VOTE RECORDED:  Walters

           SENATE APPROPRIATIONS COMMITTEE  :  6-3, 5/24/10
          AYES:  Kehoe, Alquist, Corbett, Leno, Wolk, Yee
          NOES:  Cox, Walters, Wyland
          NO VOTE RECORDED:  Denham, Price


           SUBJECT  :    Tax credits:  reporting information and  
          recapture

           SOURCE  :     California Nurses Association


           DIGEST  :    This bill requires a taxpayer doing business in  
          California that claims a tax credit to submit to the  
          Franchise Tax Board on the original return specified  
          information, including the number of employees employed by  
          the taxpayer in the state and the number of jobs created by  
          the tax credit.  This bill also requires, in cases in which  
          a taxpayer subject to the provisions of the bill has a net  
          decrease in the number of full-time employees for a credit  
          added by statute on or after January 1, 2011, the credit to  
          be disallowed and the entire amount of any credit  
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          previously allowed to be recaptured and the taxpayer to be  
          liable for any credits on previous tax returns, as  
          specified.

           ANALYSIS  :    Existing law provides various tax credits  
          designed to provide incentives for taxpayers that incur  
          certain expenses, such as child adoption, or to influence  
          behavior, including business practices and decisions, such  
          as research and development credits and Geographically  
          Targeted Economic Development Area credits.  The  
          Legislature typically enacts such tax incentives to  
          encourage taxpayers to do something but for the tax credit,  
          they would otherwise not do.

          This bill disallows certain credits that reduce taxes if  
          the taxpayer fails to achieve specified employment  
          requirements.

          This bill requires a taxpayer doing business in the state  
          under personal income tax statutes or corporation tax  
          statutes to submit to the Franchise Tax Board (FTB) on a  
          timely-filed original return the following information:

          1. The number of full time, part time, and temporary  
             employees employed by the taxpayer in the state.

          2. The amount of tax credits claimed by the taxpayer on the  
             return for each tax credit.

          This bill provides that for any tax credits added into law  
          on or after
          January 1, 2011, the credit will be disallowed and any  
          credits previously allowed will be recaptured and the  
          taxpayer will be liable for any credits on previous tax  
          returns if the taxpayer has a net decrease in the number of  
          full-time employees according to the information submitted  
          to FTB.

          The net decrease in qualified full time employees would be  
          determined on an annual full-time equivalent basis by  
          subtracting the total number of qualified full time  
          employees employed in the preceding taxable year by the  
          taxpayer and by any trade or business acquired by the  
          taxpayer during the current taxable year from the total  

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          number of full-time employees employed in the current  
          taxable year by the taxpayer and by any trade or business  
          acquired during the current taxable year.

          This bill defines "full-time equivalent" to mean either of  
          the following:

          1. In the case of a full-time employee paid hourly wages,  
             the total number of hours worked for the taxpayer by the  
             employee (not to exceed 2,000 hours per employee)  
             divided by 2,000.

          2. In the case of a salaried full-time employee, the total  
             number of weeks worked for the taxpayer by the employee  
             divided by 52.

          A part-time employee means an employee who works less than  
          an average of 35 hours in a week, calculated monthly.  A  
          temporary employee means an employee who works less than  
          120 days annually.

          The Legislative Counsel identifies a bill that imposes,  
          repeals, or materially alters a state tax as a tax levy.   
          According to FTB, this bill does not have any revenue  
          effect because it does not alter any provisions of current  
          tax law.

          FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes    
          Local:  No

          The revision of forms and instructions needed to permit the  
          filing of the necessary information would result in minor,  
          absorbable costs to FTB.

           SUPPORT  :   (Verified  5/24/10)

          California Nurses Association (source)
           Alliance of Californians for Community Empowerment
           American Federation of State, County and Municipal  
            Employees, AFL-CIO
           American Federation of Teachers Local 1521
           California Alliance for Retired Americans
           California Church Impact
           California Conference Board of the Amalgamated Transit  

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            Union
           California Conference of Machinists
           California Federation of Teachers
           California Hunger Action Coalition
           California Labor Federation
           California Professional Firefighters
           California Public Interest Research Group
           California Tax Reform Association
           California Teamsters Public Affairs Council
           Health Access California
           International Association of Theatrical and Stage  
            Employees
           International Longshore and Warehouse Union Local 6 and  
            Local 94
           Ironworkers Local 118, Local 155, and Local 377
           Napa Solano Building Trades Council
           Northern California District Council - International  
            Longshore and Warehouse Union
           Plumbers and Steamfitters Local 159
           San Mateo Building Trades Council, Plumbers and  
            Steamfitters Local 159
           Service Employees International Union
           Sierra Club California
           United Food and Commercial Workers Union Local 1428
           United Food and Commercial Workers Western States Council
           Unite-HERE International Union
           Western Center on Law and Poverty
           Western States Council

           OPPOSITION  :    (Verified  5/25/10)

          BIOCOM
          California Aerospace and Technology Association
          California Bankers Association
          California Chamber of Commerce
          California Grocers Association
          California Manufacturers and Technology Association
          California Taxpayers Association
          Irvine Chamber of Commerce
          TechAmerica

           ARGUMENTS IN SUPPORT  :    According to the author, "SB 1391  
          brings much needed transparency and accountability to  
          corporate tax expenditures.  This bill will allow the state  

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          to recoup, or 'clawback,' any future tax expenditures given  
          to a corporation that fails to meet employment or  
          investment commitments.  Specifically, this bill would  
          require corporations to annually submit to the Franchise  
          Tax Board specified information relating to how they used  
          the tax credits they received to retain or create jobs. 
          Corporations receiving tax expenditures will be required to  
          payback the entire amount of any assistance to the state if  
          the corporation has a net decrease in the number of  
          full-time employees.  Clawback provisions make tax  
          expenditures more effective, transparent, and accountable.   
          This bill will set clear expectations for corporations and  
          guarantee that the state's investment will yield measurable  
          results in the form of job retention and creation."

           ARGUMENTS IN OPPOSITION  :    The opponents believe the  
          reclamation provision of the bill is "problematic because  
          it creates uncertainty for employees, and the reliability  
          of the investment credits is what allows employers to make  
          decisions that help the state in the long run.  For  
          example, an employer might decide to employ someone in a  
          growing department, anticipating that this job would  
          qualify for a relevant credit.  If later in the year the  
          employer decides that another department is over-staffed  
          based on its current needs, this bill would consider that  
          cut to nullify the value of the earlier hire, and would  
          require the employer to return the other investment credit  
          - nevermind that such a cut might enable the employer to  
          hire someone new in another department next year.   
          Investment incentives are not beneficial to the state only  
          if they result in a net increase in jobs.  In addition,  
          hiring decisions are made based on long-term goals, not  
          strictly within the fiscal tax cycle."  
           

          DLW:mw  5/26/10   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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