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Technology & Innovation
Science and R&D Policy

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.

Innovation is the Key to Faster Economic Growth in the New Economy

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.

The R&D Credit Addresses a Clear Market Failure

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.

The Credit Effectively Stimulates Economic Growth

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.

Current Structure of the Credit

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.

Changes Needed

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.

    Summary

    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.

    Endnotes

    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).

    Robert D. Atkinson is director of the Technology, Innovation, and the New Economy Project at the Progressive Policy Institute.



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