BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1597
                                                                  Page  1

          Date of Hearing:  April 9, 2012

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Henry T. Perea, Chair
                     AB 1597 (Cook) - As Amended:  March 20, 2012

          Majority vote.  Tax levy.  Fiscal committee.
           
          SUBJECT  :  Personal income tax:  credit:  loss of income

           SUMMARY  :  Allows a credit, under the Personal Income Tax (PIT) 
          Law, equal to 10% of a taxpayer's "loss of income."  
          Specifically,  this bill  :  

          1)Defines "loss of income" as a reduction in adjusted gross 
            income (AGI) in the current taxable year from the preceding 
            taxable year of 10% or more.  

          2)Provides that the credit shall only be allowed if AGI for the 
            taxable year is less than:

             a)   $80,000 if single; and, 

             b)   $160,000 if married.  

          3)Caps the credit amount per taxable year at:

             a)   $300 for single individuals or married individuals 
               filing a separate return; and,

             b)   $600 for married couples filing a joint return.  

          4)Provides that the credit shall only be allowed if the "loss of 
            income" is not the result of:

             a)   A dismissal or termination for cause; or

             b)   A finding of guilt in a criminal proceeding or a pending 
               criminal investigation.

          5)Provides that if the credit amount exceeds the taxpayer's "net 
            tax", the excess may be carried over to reduce the "net tax" 
            in the following year, and succeeding nine years if necessary, 
            until the credit is exhausted.  









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          6)Authorizes the Franchise Tax Board (FTB) to prescribe 
            regulations necessary to administer the credit.  

          7)Applies to taxable years beginning on or after January 1, 
            2012.

          8)Takes immediate effect as a tax levy.  

           EXISTING LAW  :  Allows various tax credits under the PIT Law.  
          These credits are generally designed to encourage socially 
          beneficial behavior or to provide relief to taxpayers who incur 
          specified expenses.   
           
           FISCAL EFFECT  :  The FTB estimates that this bill would result in 
          General Fund revenue losses of $900 million in fiscal year (FY) 
          2012-13, $800 million in FY 2013-14, and $800 million in FY 
          2014-15. 

           COMMENTS  : 

          1)The author has provided the following statement in support of 
            this bill:

               AB 1597 will help Californians feel more financially secure 
               about taking lower paying jobs�,] which will help alleviate 
               some of the burden our State's 11% unemployment rate has 
               put on the �Employment Development Department].

          2)Opponents of this bill note the following:

               This is a novel bill, but is unnecessary as taxpayers 
               already pay less tax when their income declines.  If income 
               declines substantially, the taxpayer gets the benefit of 
               being in a lower bracket and paying proportionately less in 
               tax in a progressive system.  So your implicit support of 
               progressivity is appreciated, since the existence of such a 
               system provides a sufficient tax reduction when income 
               declines.  Your bill would also be particularly 
               destabilizing of the state budget, because declines 
               occurring during a recession would become exaggerated, 
               causing even further cuts.

          3)The FTB notes the following implementation and policy concerns 
            in its staff analysis of this bill:









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               The bill uses federal AGI thresholds established by marital 
               status without �regard] to filing status to determine if a 
               taxpayer is eligible for the credit.  It is unclear how the 
               federal AGI threshold would be used to limit eligibility 
               for the credit for married individuals filing separate 
               returns.  To alleviate confusion among taxpayers, it is 
               recommended that the bill be amended with AGI thresholds 
               established by filing status, instead of marital status.

               The bill bases the credit on a taxpayer's reduction in AGI 
               from the prior year.  It is unclear how the joint AGI of a 
               jointly filed return would be allocated to the two 
               individual filers for the loss calculation when there is a 
               change in filing status from one year to the next.  To 
               alleviate confusion among taxpayers, it is recommended that 
               the bill be amended to address how a change in filing 
               status would impact the allowance of the credit.

               The bill allows a credit in the amount of $300 or $600, 
               based on filing status.  The bill fails to identify all 
               filing statuses, such as head of household and surviving 
               spouse.  To avoid disputes between taxpayers and the 
               department, it is recommended that the bill be amended to 
               address all filing statuses and their corresponding credit 
               amounts.

               The bill lacks a sunset date.  Sunset dates generally are 
               provided to allow periodic review of the effectiveness of a 
               credit by the Legislature.

          4)Committee Staff Comments:

              a)   Individuals who were never unemployed will be eligible 
               for the credit  .  As noted above, this bill seeks to 
               alleviate some of the burden that California's unemployment 
               rate has put on the Employment Development Department by 
               helping unemployed Californians feel more financially 
               secure about taking lower-paying jobs.  However, there is 
               no language in this bill that explicitly limits the 
               applicability of the credit to formerly unemployed 
               individuals.  Instead, this bill allows any individual - 
               employed, unemployed, or retired - who has experienced a 
               "loss of income" of 10% or more, from one tax year to the 
               next, to be eligible for credit.









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              b)   Credit's retrospective applicability  .  This bill would 
               allow a credit for each taxable year beginning on or after 
               January 1, 2012.  It is difficult to conceptualize how a 
               retrospective credit will further the credit's purpose 
               given that the very action the credit seeks to encourage, 
               the acceptance of a lower paying job, will have taken place 
               before the credit's existence.  Committee staff recommends 
               an amendment to make the credit prospective.

              c)   Credit amount  .  This bill provides individuals or 
               couples who have experienced a loss of income of 10% or 
               more, from one tax year to the next, a tax credit equal to 
               50% of that loss, up to $300 for a single filer or $600 for 
               joint filers.  The Committee staff questions whether this 
               capped credit will be sufficient to prompt an individual to 
               accept a lower paying job in lieu of filing for, or 
               continuing to receive, unemployment benefits.  Unemployment 
               benefits could conceivably provide an individual with more 
               financial relief than a single tax credit of a few hundred 
               dollars.

              d)   Sunset date  .  This bill lacks a sunset date to allow 
               periodic legislative review of this tax expenditure.  
               Committee staff recommend an amendment to add a sunset 
               date.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          None on file

           Opposition 
           
          California Tax Reform Association
           
          Analysis Prepared by  :  Rosailda Perez / M. David Ruff / REV.  & 
          TAX. / (916) 319-2098