An Analysis of the Availability and Incentive Effects of the R&D Tax Credit after the Omnibus Budget Reconciliation Act of 1989

The U.S. Ramp;D credit has always been incremental in nature, providing a credit for qualified Ramp;D expenses exceeding some base amount. Originally, the base amount was the average of the previous three years' Ramp;D expenses (i.e., a moving average). After heavy criticism that the credit's incentive effects were largely offset in the following three years, Congress substituted the moving average base with a fixed-base as part of the Omnibus Budget Reconciliation Act of 1989. This study examines the effect of this structural change on the number of firms that are eligible for the credit and the type of firms that are eligible for the credit. In addition, we examine the incentive effect of the Ramp;D tax credit for firms that qualified for the credit, and whether the incentive effect changed after the implementation of OBRA89. Using data from 1981-1994, we find overall firm eligibility declined after OBRA89, but increased for firms belonging to high-tech industries, relative to firms belonging to other industries. Dynamic panel regressions that control for various non-tax factors indicate that median Ramp;D spending intensity of high-tech (other) firms increased approximately 15.9 (9.4) percent from 1986-1989 to 1990-1994. For qualified firms, our estimates imply approximately $2.08 of additional Ramp;D spending per revenue dollar forgone