BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2107
                                                                  Page  1

          Date of Hearing:   May 7, 2014

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                  Mike Gatto, Chair

                    AB 2107 (Gorell) - As Amended:  April 30, 2014

          Policy Committee:                              Revenue &  
          Taxation     Vote:                            9-0

          Urgency:     No                   State Mandated Local Program:  
          No     Reimbursable:              No

           SUMMARY  

          This bill creates the California Preschool Investment Pilot  
          Program (Program) to incentivize private contribution to state  
          preschools through a tax credit.  The bill establishes the  
          California Preschool Investment Fund (Fund) and allows an income  
          tax credit equal to 40% of the amount contributed by an  
          individual or corporate taxpayer to the Fund.  The bill requires  
          the California Department of Education (CDE) to use the  
          contributions to fund state preschool programs after reimbursing  
          the General Fund for credits issued and reimbursing costs to CDE  
          and the Franchise Tax Board (FTB).  In summary, this bill:

          1)Requires the CDE to select, no later than September 1, 2015,  
            the five counties to be included in the Program, ensuring that  
            urban, suburban, and rural counties are all represented.   
            Applications shall be made by county child care and  
            development planning councils.

          2)Requires the CDE to establish a procedure for making  
            contributions to the Fund and issuing receipts to contributors  
            indicating the amount contributed, the name of the  
            contributor, the date the contribution is made, and whether  
            the person has been allocated a tax credit.

          3)Allows the taxpayer to claim the credit only if the taxpayer  
            provides the receipt from CDE to the FTB and claims the credit  
            on a timely filed original return.  The bill allows the  
            taxpayer to carry forward any unused credit for up to four  
            years.

          4)Requires that moneys distributed from the Fund be used first  








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            to reimburse the General Fund for the aggregate amount of  
            certified credits allowed; second, upon appropriation, to the  
            CDE and FTB to reimburse administrative costs associated with  
            the Program; and last, upon appropriation, to support state  
            preschools located in the five participating counties.

          5)Limits the aggregate amount of credits that may be allowed to  
            $250 million per calendar year; specifies that credits will be  
            allocated to contributors on a first come, first served basis.  


          6)Requires the CDE to notify the FTB of the credits allocated on  
            a monthly basis, and requires the CDE and FTB to post that  
            information quarterly on their respective websites, together  
            with the amount of remaining credits and an indication of  
            whether the cap on credits may be reached at least every  
            calendar quarter.

          7)Specifies that any moneys remaining in the Fund as at January  
            1, 2020 shall be transferred to any other state fund  
            identified by the CDE that provides funding for increased  
            access to preschool programs for low-income children.

           FISCAL EFFECT  

          1)Potential costs, likely in the hundreds of thousands of  
            dollars, to CDE in the hundreds of thousands to administer the  
            Fund and provide contribution receipts; additional minor costs  
            to FTB to administer the tax credit.

          2)Estimated decrease to GF revenue of $2.2 million in FY  
            2014-15, $17.0 million in FY 2015-16, and $19.0 million in FY  
            2016-17, though this bill seeks to reimburse the GF for those  
            amounts.

           COMMENTS  

          1)  Purpose.   According to the author, demand for early learning  
            programs outstrips supply, with many families on waitlists for  
            state programs.  The author indicates that several studies  
            have shown the beneficial impact to students of early  
            learning, and that early investment in child learning yields  
            long-term economic benefit to the state.

            The author contends the Program will provide incentives for  








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            private sector businesses to contribute to the state's current  
            early learning programs and allow more families to send their  
            children to preschools.  The author claims other states have  
            demonstrated evidence of significant interest from large  
            corporations in contributing to early education.

          2)  Interaction with Federal Charitable Contributions.   This bill  
            is based on a recent idea to "capture" federal dollars by  
            enacting a state charitable tax credit.  Based on recent IRS  
            guidance that charitable contributions to a state fund are  
            eligible for the federal tax deduction in the same manner as  
            contributions to a charitable non-profit organization, the  
            structure allows a taxpayer to benefit from both the state tax  
            credit as well as a full deduction on the contribution amount  
            from federal taxes.  Such a favorable structure could result  
            in the state raising significant money for this Fund, serving  
            as a model to future programs.

          3)  Generous Incentive.   This bill creates one of the most  
            generous tax credits ever allowed in California.  Under  
            existing law, taxpayers may only claim a deduction for  
            contributions to charitable organizations.  A tax credit,  
            however, may be much more valuable, particularly to corporate  
            taxpayers, which are limited to 10% of the taxpayer's net  
            income.  As a result, this bill could incentivize many  
            corporate taxpayers to redirect charitable contributions to  
            the Fund, creating a tax planning opportunity for corporate  
            social responsibility programs.

          4)  Previous Legislation.   SB 284 (De Leon) in 2013 would have  
            established a similar tax credit and voluntary contribution  
            fund with a structure similar to that contemplated here.  SB  
            284 was vetoed by the Governor because it would have adversely  
            impacted Proposition 98 funding guarantee.


           Analysis Prepared by  :    Joel Tashjian / APPR. / (916) 319-2081