PPI | Briefing | May 1, 1999
Boosting Technological Innovation Through the Research and Experimentation Tax Credit By Robert D. Atkinson
Technological innovation is the major factor driving economic and
income growth in America today, and one of the key federal (and state1) policy tools used to stimulate this
innovation is the research and experimentation tax credit. Commonly
known as the R&D credit, it provides tax incentives for firms to invest in
research and development. But partly because of how the cost would have
to be scored in the budget, the credit has never been made permanent.
Instead, since its enactment in 1981, the credit has been extended nine
times and the lack of permanence is only one of many factors that limit
the credit's effectiveness.
The new realities of technological innovation require not only
that the credit be made permanent, but also that it be updated to more
effectively promote innovation in the New Economy. A number of bills
from the 105th Congress, and now in the 106th, would address one or
more aspects of the credit. But one bill, S 951, introduced this month by
Senators Pete Domenici (R-NM), Jeff Bingaman (D-NM), Joe Lieberman
(D-CT), Bill Frist (R-TN) and Olympia Snowe (R-ME) represents the kind
of comprehensive modernization of the credit that is needed. In the
House, a companion bill (H.R. 1682) was introduced by Representatives
Heather Wilson (R-NM), Harold Ford (D-TN), Tom Udall (D-NM), and
Joe Skeen (R-NM). Not only do the bills propose making the credit
permanent, they also include a number of important reforms to make the
R&D tax credit a more effective tool for stimulating research in the New
Economy. These provisions include: modifying the credit's two-tier
structure to give more firms access to the higher marginal rate; creating a
collaborative R&D credit; and making it easier for new entrepreneurial
firms to take advantage of the credit.
The Joint Committee on Taxation has estimated that the
comprehensive improvements of the sort envisioned by the Domenici-
Bingaman bill can be achieved for $38 billion over 10 years ($3.8 billion
per year), compared to approximately $28 billion for just making the
credit permanent and not reforming it.
There is clear consensus among economists that investment in
research fosters the lion's share of our economic and productivity growth.
At least two-thirds of per capita economic growth stems directly from
technological innovation.2 A one
percent increase in the nation's investment in research increases
productivity 0.23 percent.3 This
is important because slow growth in productivity in the last two decades
has been the factor most responsible for slow growth in wages for
American workers. Boosting technological innovation and adoption is the
prerequisite to raising wages; if productivity had increased after 1973 the
way it did in the 30 years before, half of all American households would
now be earning at least $63,000 instead of the current $37,000. Boosting
productivity even a half a percent more than baseline forecasts over the
next 30 years can go a long way toward addressing the looming retirement
crisis stemming from too few workers supporting too many retirees.
Firms seldom capture all of the benefits of research, particularly
riskier, early-stage research. Research results can often be used by more
than one firm firms can often utilize the results of others' research to
improve their own products and processes at a fraction of the cost of
doing their own original research. As result, the benefits to society from
a company's R&D investments are significantly higher than the company's
own rate of return.
Numerous studies by economists, including the President's
Council of Economic Advisers, have found that the public rates of return
on R&D are at least twice the estimated private returns.4 The large difference between the
private and public rates of return means that absent public action, industry
under-invests in R&D, particularly earlier stage R&D.5 And, significantly heightened
business competition in the New Economy is making this even more
pronounced. Industry cut its investment in basic research 4.6 percent per
year from 1991 to 1995.6 This
kind of market failure means that government incentives to stimulate
private research and reduce the difference between the private and public
rates of return are needed to obtain the optimal levels of research in the
economy.
This market failure is also why many other nations provide
generous R&D tax credits. For example, the Canadian government
provides a flat, non-incremental 20 percent R&D credit for large
companies, and up to a 35 percent credit for small companies. Provincial
government credits are added to these. For example, companies in
Quebec receive an additional 20 percent credit for internal R&D expenses,
and a 40 percent credit for collaborative R&D with universities or
consortia.
There is general agreement that the R&D tax credit has been a cost-
effective policy tool. For example, the former Congressional Office of
Technology Assessment concluded that "for every dollar lost in tax
revenue, the R&D tax credit produces a dollar increase in reported R&D
spending, on the margin."7
Other studies have found even greater benefits, with the economic benefit
to tax-cost ratio between 1.3 and 2.0. A recent study by Coopers &
Lybrand estimated that if the R&D tax credit were made permanent (as
opposed to being repealed), companies would spend $41 billion more on
R&D over the next 12 years, boosting productivity and adding $13 billion
(in 1998 dollars) in economic output per year by 2010.8 Because higher productivity results
in lower relative prices, the benefit of the higher productivity triggered by
the R&D tax credit would be equivalent to a $47 billion tax cut for families
over 13 years. By 2010, Coopers & Lybrand estimates that the credit
would generate net higher tax revenues that would offset 47 percent of the
"static" revenue loss to the government of the credit. In the
long run, they estimate that since the benefits continue to accrue, the
credit would pay for itself through increased tax collections. All of these
studies, however, are premised on economic analyses of the credit during
the 1980s, when most firms could qualify for the incremental credit. It is
not clear that, absent reforms in the credit as described below, the cost
effectiveness of the credit will remain as positive.
The 1999 Omnibus spending bill (P.L. 105-297) retroactively
extended the R&D tax credit for one year from July 1, 1998, to June 30,
1999. Under current law, it allows firms to take one of two types of credit.
Under the regular credit, a taxpayer's current-year "qualified research
expenses," in excess of a specified base amount, are eligible for a 20
percent tax credit. The base amount is a ratio of R&D expenses relative
to sales for the years 1984 to 1988. Because the base period is fixed, many
firms do not qualify for the credit because their R&D-to-sales ratio is
higher in the base period than it is now. This is the case for many firms
that have merged, downsized, faced defense spending cuts, or otherwise
restructured, or that for a particular reason had either low sales during the
period or very high spikes in R&D spending. As a result, in order to
stimulate R&D at these kinds of firms, Congress created the Alternative
Incremental Credit in 1996. Firms that cannot qualify for the regular
credit can take a credit of between 1.65 percent and 2.75 percent of
qualified research expenses in excess of 1 percent of a company's average
annual gross receipts.
Also, firms started after 1988 can use the regular credit. They
just have to contend with the complex base phase-in rules which are
unfavorable for a lot of small, high-tech startups.
If the R&D credit is to play a renewed role in fostering innovation in
the New Economy, a number of changes are needed, all of which would
be accomplished under the Bingaman-Domenici bill. These include:
Making it Permanent. Until now, neither Congress nor the
Administration has attempted to make the credit permanent. Rather, they
have reauthorized it one year at a time, often at the last minute,
retroactively, after the credit has actually expired. The uncertainty over
whether the credit will be in place adds risk to the already risky R&D
investments made by companies, and it reduces the effectiveness of the
credit. The major reason Congress has not made the credit permanent is
because it requires the expenditures be scored for five years, raising the
budgeted cost. However, extending the credit each year in lieu of
permanence does not actually lower the cost to government. Rather, it
allows the costs to be posted to later-year budgets.
In addition to S.951 and H.R. 1682, several other bills
have also been introduced proposing to make the credit
permanent, including H.R. 947, introduced in the 105th
Congress by Representatives Nancy Johnson (R-CT) and
Robert Matsui (D-CA), and S. 195, introduced by Senator
Barbara Boxer (D-CA) in the 106th Congress.
Reforming the Alternative Minimum Credit. Congress created the
alternative
credit to allow a broader range of firms, including firms started after 1988,
to qualify for the credit. While the alternative credit helps firms that do
not qualify for the regular credit, its marginal value (between 1.65 percent
and 2.75 percent) is a minimal incentive for firms to increase research.
Firms currently qualifying for this credit need a way of
"graduating" to the regular base period credit.
The best way to do this is to institute a new "rolling"
base period that lets firms obtain the 20 percent credit on research
investments in excess of their base period level. S.951 and H.R. 1682
would let firms qualify for the regular incremental credit by using their
average R&D-to-sales ratio of the prior 8 years as their base period.
Instituting a rolling base period is important so that new firms and firms
with significantly changed R&D intensities do not get locked out of the
regular credit. As an incentive for firms to switch to the more efficient
rolling base period, the bill also provides firms with a more generous flat
alternative credit on the amount of expenses equal to the base period
expenses.9 Firms that choose to
take the original credit with the 1984-88 base period would not be required
to switch to the new credit. However, instead of raising the alternative
minimum credit amount, Congress should consider raising the incremental
credit itself (perhaps to 25 percent) for firms that choose to adopt the
rolling base period credit.
Expanding the Credit to Support Collaborative R&D.In the New
Economy, collaborative R&D has become an important feature of
technological innovation.10
Increasingly, firms are collaborating with other firms or institutions in
order to lower the costs of research and increase their effectiveness by
maximizing idea flow and creativity. Yet, collaborative research whether
in partnership with a university, national laboratory, or industry
consortium is more likely to be basic exploratory research than the
research typically conducted by a single company. Moreover, because the
research is shared from its inception, the benefits are less likely to be fully
captured by an individual firm. For example, spillovers from company-
funded basic research are very high over 150 percent according to one
study.11 Because spillovers from
collaborative research are likely to be particularly great, firms will tend to
under-invest in this approach even more than in individual research. Thus,
the federal government should more generously support collaborative
research through the R&D credit.
The Progressive Policy Institute (PPI) has proposed that all company
expenditures on collaborative R&D, not just incremental expenditures, be
eligible for a 20 percent credit.12
A bill, H.R. 3857, introduced in May 1998 by Representatives Amo
Houghton (R-NY) and Sander Levin (D-MI) with bipartisan support
proposed amending the IRS code to allow a 20 percent research credit for
expenses attributable to collaborative research consortia. This year, S. 951
and H.R. 1682, consistent with PPI's recommendations, would extend the
credit not only to these kinds of collaborations but also to any industry-
university or industry-federal laboratory research, as long as the research
results are made public.
The credit should also be modified to ensure that all expenses
for contract research are eligible. Currently, only 65 percent of contract
research expenses (e.g., at universities, small businesses, and research
laboratories) are eligible for the credit. S. 951 and H.R. 1682 allow 100
percent of expenses to be classified as eligible research
expenses.
Making it Easier for Small and New Businesses to Access the Credit. New
and young technology-based companies play a key role in driving
innovation and creating jobs. Yet, aspects of the credit make it difficult
for these kinds of companies to use it. Most importantly, many new
technology-related start-ups invest significant amounts on R&D before
they generate any sales. Current rules limit the usefulness of the credit for
them. One solution, as proposed by S.951 and H.R. 1682, would allow
small and new firms to claim, for any taxable year in the base period, gross
receipts at least equal to $1 million.
In addition, Congress should consider making a portion of the credit
refundable to start-up companies that have no tax liability to offset. Now
the credit can be carried forward seven years, but for many start-ups with
very little cash flow, this provision provides little incentive. Congress
could allow start-ups to receive an immediate tax credit on a share of the
credit (e.g. 50 percent) they are eligible for, while still enabling them to
carry forward the remainder of the credits.
Simplifying the Credit. Current rules defining "qualified
research" rely on a Treasury Department definition. The broader
and more widely used definition comes from Financial Services
Accounting Board (FASB) rules, which is consistent with the National
Science Foundation survey definition, and familiar to many firms. As it is,
firms often end up using two separate accounting methods if they are to
take the credit. Because of its expense, this provision has not been
included in any of the bills.
Growth in the New Economy is increasingly driven by innovation
born of investments in research. Thus, by encouraging greater public and
private investments in such research, government policy can play an
important role in spurring economic growth. The R&D tax credit is the
right approach. But the time has come 20 years after its
introduction for a number of key strategic changes to make the credit
more effective. The bills discussed above, S. 951 and H.R. 1682, represent
a needed and comprehensive overhaul of the bill, not the least of which is
to make the credit permanent. This is the kind of policy innovation
needed to drive technological innovation and economic growth in the
New Economy.
1. In 1996, 35 states offered an R&D tax credit that allows firms to piggyback on credits
offered by
the federal government. At an additional 22.5 percent, Rhode Island offers the most generous
state R&D
tax credit.
2. Kenan Patrick Jarboe and Robert D. Atkinson, The Case for
Technology in the Knowledge Economy: R&D, Economic Growth, and the Role of Government
(Washington, DC: Progressive Policy Institute, June 1998).
3. D. Coe and E. Helpman, "International R&D Spillovers," European
Economic Review 39, 1995.
4. Council of Economic Advisors, Economic Report to the President, 1995.
5. Kenan Patrick Jarboe and Robert D. Atkinson, The Case for Technology in the
Knowledge Economy: R&D, Economic Growth, and the Role of Government
(Washington, DC: Progressive Policy Institute, June 1998).
6. National Science Foundation, Science and Engineering Indicators, 1996.
The Industrial Research Institute also reports that since 1993, the number of companies surveyed
who reported that they were increasing total R&D more than 5 percent was more than twice as
high as those reporting similar increases in basic research. The average length of an industry
basic
research project dropped from 21.6 months in 1991 to 16.7 months in 1996.
7. U.S. Congress, Office of Technology Assessment, "The Effectiveness of Research
and Experimental Tax Credits," (Washington DC: U.S. Government Printing Office,
1995).
8. Coopers and Lybrand, "Economic Benefits of the R&D Tax Credit," 1998.
9. As an additional incentive to get firms to switch from the old credit to the new rolling
base
year credit, the bill eliminates the so-called "50 percent" for the new alternative
credit.
This rule reduces the value of the credit that firms can take.
10. The Progressive Policy Institute has published a report
illustrating what's actually new about the so-called "New
Economy." The report describes the impact of collaborative
R&D in greater detail. Robert D. Atkinson and Randolph H. Court,
The New Economy Index: Understanding America's Economic Transformation
(Washington, DC: Progressive Policy Institute, November 1998).
11. Link, A. N. 1981, "Basic Research and Productivity Increase in
Manufacturing," American Economic Review 71, pp. 1111-1112.
12. Jane Fountain and Robert Atkinson, Innovation and Social Capital,
(Washington, DC: Progressive Policy Institute, June 1998).
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