BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1474
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          Date of Hearing:  May 18, 2009

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                             Charles M. Calderon, Chair

                     AB 1474 (Cook) - As Amended:  April 2, 2009

                                      SUSPENSE
          
          Majority vote.  Tax levy.  Fiscal committee.

           SUBJECT  :  Sales and use taxes:  exemption:  mobilehomes

           SUMMARY  :  Exempts new mobilehomes from the recently enacted 1%  
          sales and use tax (SUT) increase under specified conditions.   
          Specifically,  this bill  :

          1)Exempts a new mobilehome from the recently enacted 1% SUT  
            increase if both of the following conditions are met:

             a)   The mobilehome is sold by a retailer to a purchaser  
               under the circumstances described in Revenue and Taxation  
               Code (R&TC) Section 6012.8 or 6012.9 (i.e., sold for  
               occupancy as a residence); and,

             b)   The purchaser's contract was entered into on or before  
               February 20, 2009, and the sale to the purchaser occurs on  
               or after April 1, 2009.  

          1)Takes immediate effect as a tax levy. 

           EXISTING LAW  :

          1)Imposes a sales tax on retailers for the privilege of selling  
            tangible personal property (TPP), absent a specific exemption.  
             The tax is based upon the gross receipts from sales of TPP in  
            this state.  

          2)Imposes a use tax on the storage, use, or other consumption in  
            this state of TPP purchased from any retailer for storage,  
            use, or other consumption in this state, absent a specific  
            exemption.

          3)Imposes, as of April 1, 2009, an additional SUT at the rate of  
            1%.  








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          4)Provides, under R&TC Sections 6012.8 and 6012.9, that:

             a)   "Gross receipts" from the sale of a new mobilehome shall  
               be 75% of the sales price of the mobilehome to the  
               retailer, if the mobilehome is sold by the retailer to the  
               purchaser for occupancy as a residence, and is thereafter  
               subject to property taxation;

             b)   The retailer shall be considered to be the consumer if  
               the retailer's sale would otherwise have been subject to  
               sales tax and if the retailer is not also the manufacturer  
               of the mobilehome; 

             c)   If the retailer of the mobilehome is the manufacturer,  
               tax shall be measured by an amount equal to 75% of the  
               sales price at which a similar mobilehome would be sold by  
               the manufacturer to a retailer-consumer in this state; and,  


             d)   A retailer may give a resale certificate for the  
               retailer's purchase of such a mobilehome and report the  
               gross receipts or sales price from the purchase with the  
               return for the period during which the mobilehome is sold  
               to the purchaser for occupancy as a residence.  

           FISCAL EFFECT  :  The Board of Equalization (BOE) has issued a  
          revised estimate projecting General Fund revenue losses of  
          $146,000. 

           COMMENTS  :

          1)The author states, "The manufacture and purchase of a  
            manufactured home is a unique process, which often  
            incorporates product-specific financing and customization at  
            the factory.  Occasionally, this results in delays in  
            financing, manufacturing, and installation.  Due to the recent  
            state sales tax increase, for the handful of purchases in  
            California, delays resulted in a price increase before  
            installation of the home.  Many purchasers of manufactured  
            homes live on limited incomes, such as seniors, and this price  
            increase might mean that they can no longer afford the  
            American dream of home ownership.  This bill will provide  
            relief to these purchasers by exempting them from the sales  
            tax increase, if they were under contract prior to the sales  








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            tax increase."

          2)Proponents state, "[T]here are unique nuances - and sometimes  
            delays - involved with the financing, construction, and final  
            installation of a manufactured home.  We, therefore, support  
            AB 1474 (Cook), which allows those buyers who purchased  
            manufactured homes under contract, on or before the enactment  
            of the sales tax increase, to be granted a refund from the  
            Board of Equalization after issuance of a certificate of  
            occupancy."

          3)Opponents state, "We do not see a rationale for exempting  
            mobilehomes from the temporary 1% across the board sales tax  
            increase.  The taxable price of a mobilehome is already 75% of  
            the sales price, so the increase is actually less than that  
            paid on other sales."

          4)BOE comments:

             a)   "Under the law, [R&TC] Sections 6012.8 and 6012.9  
               provide that a sale of a new manufactured home that is sold  
               for installation for occupancy as a residence is subject to  
               tax based on 75 percent of the selling price of the  
               manufactured home to the retailer.  In cases where a new  
               manufactured home is sold by a manufacturer directly to the  
               purchaser under similar circumstances, current law provides  
               that the tax is measured by an amount equal to 75 percent  
               of the sales price at which a similar manufactured home  
               ready for installation would be sold by the manufacturer to  
               a California dealer.

               Under these provisions, the law considers a manufactured  
               home dealer a 'retailer-consumer' of any new manufactured  
               home sold to a customer for occupancy as a residence.  As a  
               dealer who is a retailer-consumer of a manufactured home,  
               the imposition of the use tax is upon the dealer, and sales  
               tax does not apply to the amount the dealer charges the  
               customer for the manufactured home or any integral items  
               the dealer attaches to it such as carpeting, wall paneling,  
               room partitions, and built-in appliances.  As a  
               retailer-consumer, the mobile home dealer may not collect  
               an amount for tax reimbursement from his or her customer.

               Generally, the dealer owes the use tax as of the date he or  
               she sells the manufactured home.  Generally, the date of  








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               sale is considered the date the dealer transfers title  
               (ownership) to the purchaser."

             b)   BOE also notes that, "As a retailer-consumer, for mobile  
               homes sold for occupancy as residences, the mobile home  
               dealer may not collect an amount for tax reimbursement from  
               his or her customer.  As a result, for manufactured homes  
               sold for occupancy as residences within the time specified  
               in this bill, the bill would enable the dealer to claim a  
               refund for the 1 percent use tax portion.  However, that  
               refund would not be required to be passed on to the  
               customer (unless the dealer inappropriately collected the  
               tax reimbursement from the customer)."

             c)   Finally, BOE notes, "Escrow is used for a variety of  
               high ticket items, including specialized automobiles,  
               motorcycles, jewelry, computer equipment, and so on.  A  
               similar argument could be made for other items ordered  
               prior to the rate increase, but delivered after the  
               effective date of the increase."

          5)Committee staff notes:

              a)   Who does this bill help  ?  Proponents of this bill note  
               that many mobilehome buyers live on limited incomes.  In  
               addition, they state that without this exemption, these  
               individuals may no longer be able to afford the American  
               dream of home ownership.  It should be noted, however, that  
               under existing law, it is the mobilehome retailer who would  
               be on the hook for the SUT increase, and not the buyer.   
               Thus, while not detracting from the equities involved, this  
               bill can more accurately be described as assisting  
               mobilehome retailers.  

              b)   Related legislation :  AB 1523 (Calderon), introduced in  
               the current Legislative Session, would exempt from the 1%  
               SUT increase sales of TPP made under fixed price contracts  
               entered into before the date of the rate increase.  AB 1523  
               is set to be heard by this Committee on May 18, 2009.  

           REGISTERED SUPPORT / OPPOSITION  :   

          Support 
           
          California Manufactured Housing Institute








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          Western Manufactured Housing Communities Association

           Opposition 
           
          American Federation of State, County and Municipal Employees,  
          AFL-CIO
          California Tax Reform Association
           
          Analysis Prepared by  :  M. David Ruff / REV. & TAX. / (916)  
          319-2098