BILL ANALYSIS
AB 2492
Page 1
Date of Hearing: May 10, 2010
ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
Anthony J. Portantino, Chair
AB 2492 (Ammiano) - As Amended: May 3, 2010
Majority vote. Tax levy. Fiscal committee.
SUBJECT : Property taxation: change in ownership.
SUMMARY : Revises the circumstances under which a "change in
ownership" of real property owned by a legal entity is deemed to
have occurred. Specifically, this bill :
1)Provides that, when 100% of ownership interests in a legal
entity are sold or transferred in a single transaction, the
purchase or transfer of that interest is considered to be a
"change of ownership" of the real property owned by the
entity, thus, triggering a reassessment of the property for
tax purposes.
2)Specifies that a "sale or transfer" of ownership interests in
a legal entity means a merger, acquisition, private equity
buyout, transfer of partnership shares, or any other means by
which a legal entity acquires the ownership interest of
another legal entity, including the subsidiaries or affiliates
of the legal entity and the property owned by those
subsidiaries and affiliates.
3)States that a purchase or transfer of 100% of ownership
interests in a legal entity is considered to be a "change of
ownership" of the real property owned by that entity, whether
or not any one legal entity that is a party to the transaction
acquires more than 50% of the ownership interests.
4)Requires the State Board of Equalization (BOE) to notify
assessors when such a change in ownership has occurred.
5)Defines the term "legal entity" as a corporation, a
partnership, a limited liability company, or other legal
entity.
6)Defines the phrase "ownership interests" as corporate voting
stock, partnership capital and profits interests, limited
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liability company membership interests, and other ownership
interests in legal entities.
7)Requires the BOE to prescribe regulations that may be
necessary to carry out the purposes of this bill.
8)Contains a statement of legislative intent to specify
circumstances under which real property owned by banks and
financial institutions, which have been acquired by other
financial institutions, undergo a "change in ownership."
9)Takes effect immediately as a tax levy.
EXISTING LAW :
1)Provides that all property is taxable, unless otherwise
provided by the California Constitution or federal laws,
[Section 1(a), Article XIII, California Constitution]. Limits
ad valorem taxes on real property to 1% of the full cash value
of that property (Proposition 13).
2)Requires real property to be reassessed to its current fair
market value whenever a "change in ownership" occurs.
[California Constitution, Article XIII A, Section 2; Revenue
and Taxation Code (R&TC) Sections 60 - 69.5].
3)Provides that "change in ownership" includes a transfer of any
interest in real property between a corporation, partnership,
or other legal entity and a shareholder, partner or any other
person. [R&TC Section 61(j)].
4)Specifies in Revenue and Taxation Code (RT&C) Sections 60
through 69.5 what constitutes "a change in ownership." Sets
forth the general rule that, when real property is owned by a
legal entity, the purchase or transfer of ownership interests
in that entity does not trigger a change in ownership of the
property, unless a) there is a "change in control" of the
legal entity or b) one person or entity acquires more than 50%
of the ownership interest of the entity. [R&TC Section 64].
Thus, when any person or entity obtains control, through
direct or indirect ownership or control, of more than 50% of
the voting stock of a corporation, or a majority ownership
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interest in any other type of legal entity, a reassessment of
real property owned by the acquired legal entity (or any of
its subsidiaries) is triggered. [R&TC Section 64(c)(1)(A)].
Furthermore, when voting stock or other ownership interests
representing cumulatively more than 50% of the total interest
in a legal entity is transferred by any of the "original
co-owners" in one or more transactions, the real property that
was previously excluded from reappraisal will be reassessed.
[R&TC Section 64(d)].
5)Generally, when real property is owned by a homeowner, the
purchase or transfer or ownership interests in that entity
triggers a change in ownership of the property. However,
specific exemptions from reassessment are provided for
intra-family transfers, replacement residences of senior
citizens and disabled persons, and specific types of home
improvements.
6)Requires business personal property to be reassessed annually
at its current market value. Personal property owned by a
homeowner is not generally subject to property taxation.
FISCAL EFFECT : Unknown.
COMMENTS :
1)Author's Statement . The author states that, "The current
system for assessing and taxing commercial and industrial
property in California is riddled with loopholes. The current
system provides property owners with innumerable ways to
structure change of ownership transactions to avoid paying
higher taxes. The system allows billions of dollars of
valuable business property to be vastly under assessed,
creates great differences in taxes paid among property owners,
resulting in inadequate funding of local governments, schools
and infrastructure projects.
"Current law requires that commercial properties be taxed on
their full market value if a 'change of ownership' occurs. 'A
change of ownership' triggers reassessment of property for
property tax purposes. However, current law says that a
'change of ownership' does not occur unless one owner acquires
more than 50% of a property. Unfortunately, loopholes in
existing law have not triggered reassessment, in some cases,
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even if 100% of property has changed hands.
"Commercial property is held in many complex ways - limited
liability corporations, limited partnerships, real estate
investment trusts, family trusts, publicly traded
corporations, etc. It is often difficult to identify a
'change of ownership' under current law, and very easy to
avoid a 'change of ownership' even when a sale occurs that
should trigger a reassessment.
"In 2008, as the nation became consumed by the worst economic
recession in history - caused in no small part by the collapse
of the mortgage lending industry - and as 'too big to fail'
businesses clearly began to fail, many of the smaller lending
institutions were acquired by the larger national and
international financial institutions. However, it is still
unclear if any of the California assets acquired in these
mergers have been reassessed even though it is reasonable to
assume that 100% of ownership has changed hands.
"AB 2492 begins the process of major property tax reform by
closing the most obvious and egregious loopholes in property
tax law by requiring that where 100% of a company changes
ownership, from bank mergers and private equity buyouts, the
property held by that company and its subsidiaries and
affiliates must be reassessed, no matter how many purchasers
take ownership of the property."
2)Arguments in Support . The proponents argue that this bill is
necessary to close the major loophole in the tax system that
allows an avoidance of property reassessment even where 100%
of a business entity changes ownership. Major corporations
routinely are bought and sold without triggering a
reassessment for property tax purposes, and this loophole is
"estimated to cost state and local governments close to $1
billion ? in property tax revenues every year which could be
used to pay for vital local and state government programs and
services, including education, health care, public safety, and
transportation." The proponents assert that this bill "would
tighten the law about when a change of ownership occurs so
that it will be more difficult to avoid reassessment when
these commercial transactions take place." Finally, the
proponents state that "the loophole in the commercial property
reassessment process violates the principles of tax equity"
where "building owners with property sitting right next to
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each other on the same street in the same city could pay
vastly different tax [sic] depending [on] whether one evaded
reassessment."
3)Arguments in Opposition . The opponents argue that this bill
would remove Proposition 13 protection from business property
owners "by imposing a 'split roll' property tax that targets
our state's employers for a significant increase in property
taxes and onerous new tax burdens." The opponents state that
split roll tax proposals, in general, "are based on the faulty
assumption that there has been a major statewide shift in tax
burden from businesses to homeowners," where, in fact,
"commercial properties contribute significantly in tax dollars
- generating approximately two-thirds of the property tax
revenues, just as they did before the passage of Proposition
13." Finally, the opponents believe that the increase in the
property taxes paid by the affected entities will result in
higher prices for goods and services, a reduction in
California's competitiveness, a decrease in profits to owners
and investors, and lower wages for employees, and will overall
harm the California economy.
4)Background: Proposition 13 and "Change in Ownership" . The
property tax applies to all classes of property and is one of
the major general revenue sources for local governments in
California. It is imposed on the property owners and is based
on the value of the property. Much of the law pertaining to
taxation of property is prescribed by the California
Constitution, Article XIII and Article XIII A. Since the
adoption of Proposition 13 in 1978, real property has,
generally, been taxed based on its value at the time of its
acquisition, with increases for inflation limited to 2% per
year. Once the ownership of property is changed, the value of
the property is re-determined based on the current market
value. While the requirement to reassess property upon a
change in ownership is contained in the California
Constitution, the phrase "change in ownership" is not defined.
Shortly after the passage of Proposition 13, this Committee
appointed a special Task Force - a broad-based 35-member panel
that included legislative and BOE staff, county assessors,
attorneys in the public and private sectors, and trade
associations - to recommend the statutory implementation for
Proposition 13, including the "change in ownership"
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provisions. With respect to a transfer of ownership interest
in a legal entity that owns real property, the Task Force
initially recommended adopting the "separate entity" theory
that respects the separate identity of the legal entity.
According to this theory, so long as the legal entity owned
the property, the property will not be reassessed, even if
most or all of the ownership interests in the entity, i.e.
stock or partnership interests, had been transferred. The
Task Force recommended the "separate entity" approach because
of the perceived administrative and enforcements problems with
disregarding the separate identity of a legal entity and the
unpredictable ripple effects of ignoring the general separate
entity laws.
However, subsequently, the "majority-takeover-of-corporate
stock" provision was added "out of a concern that, given the
lower turnover rate of corporate property, mergers or other
transfer of majority controlling ownership should result in a
reappraisal of the corporation's property - an effort to
maintain some parity with the increasing relative tax burden
of residential property statewide, due to more rapid turnover
of homes." (Implementation of Proposition 13, Volume 1,
Property Tax Assessment, a report prepared by the Assembly
Revenue and Taxation Committee, California State Assembly
Publication 748, October 29, 1979). Thus, the law was amended
to provide that, whenever any person or entity has purchased
or otherwise acquired more than 50% ownership of a corporation
or other legal entity, any real property owned by the acquired
entity must be reappraised to full market value.
It should be noted that, while the Task Force, in order to
mitigate administrative difficulties, recommended the
"separate entity" approach for determining when a change in
ownership of real property occurs, it was concerned with the
fact that commercial and industrial properties change
ownership less frequently than residential property and
proposed that the Legislature study the idea of a
constitutional amendment to appraise commercial and industrial
property periodically at current market value.
5)Shift in Property Tax Burden: Myth or Reality ? It has been
argued that there are fewer opportunities for local
governments to reassess commercial properties at fair market
value because a change in ownership of nonresidential
commercial properties does not occur as often as a change in
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ownership of residential properties. At the same time, all
property owners, regardless of their property tax burden,
equally benefit from the public services paid for through
taxes. As noted by some commentators, "if a building catches
on fire, or a business is being robbed, publicly funded
emergency workers will rush to the scene as quickly for a
property owner paying $7,000 a year as they will for one
paying $66,000." (The Almanac, March 16, 2010, Who is
prospering from Proposition 13?).
Is there a disparity in the share of property tax revenues paid
by homeowners relative to businesses? Statistics from the BOE
show that the share of assessed value from owner occupied
homes has increased from 33.6% in 1979-80 to 38.1% in 2008-09.
The data from a recent report prepared by the sponsor
demonstrates a similar trend. It appears that the share of
the property tax borne by residential property has increased
in virtually every county in the state since the passage of
Proposition 13, while the share of the property tax borne by
non-residential property has decreased. (L. Goldberg and D.
Kersten, System Failure: California's Loophole-Ridden
Commercial Property Tax, May 2010, p. 3, "CTRA Report"). For
example, the amount of residential property tax in Los Angeles
County increased from 40% of the total property tax revenue in
1979 to 56% in 2009, while the amount of commercial and
industrial property tax decreased over the same time period
from 47% to 31% of the total. Similarly, in San Francisco
County, the percentage of residential property tax revenue
increased from 41% in 1979 to 57% in 2009, while the
percentage of commercial property tax revenue decreased from a
59% to a 43% in revenue share, according to the San Francisco
Assessor's Office.
However, some researchers believe that California's current
property tax system has not shifted the property tax burden
from businesses to homeowners. Thus, a report, which was
prepared at the request of Californians Against Higher
Property Taxes, asserts that Proposition 13 actually shifted
the property tax burden from owner-occupied residential
property to commercial property. (J. Alberro and W. Hamm, The
Economic Effects of California Adopting a Split Roll Property
Tax, September 2008). Using data obtained from the BOE, the
authors of the report calculated the disparity between
assessed value and market value for two classes of property:
owner-occupied residential and commercial/industrial property.
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The findings showed that "the assessed-value-to-market-value
ratio for owner-occupied residential property in the 2006-2007
roll was 53%, while the ratio for commercial and industrial
property was nearly 60%." (Id., p. vii), suggesting that
commercial property is being taxed more closely to market than
residential property. It is unclear whether these findings
accounted for the fact that certain state-assessed properties,
such as natural gas and electricity utilities,
telecommunications providers, and railroad companies are
assessed at market value under current law.
6)Is There a Problem With the Existing "Change of Ownership"
Definition ? The current system provides property owners with
several ways to structure "change in ownership" transactions
to avoid paying higher property taxes and allows purchasers to
avoid reassessment even if 100% of a company changes hands. A
business may avoid a major reappraisal of the property of an
acquired entity by simply structuring the acquisition in a way
that prevents any of the separate purchasers from receiving
more than 50% ownership in the acquired entity. Thus, if
multiple individuals or entities acquire another entity, in a
single transaction, but none of the purchasers acquires more
than 50% interest in the entity, then a reappraisal of the
property held by the acquired entity is not required.
As noted by the Senate Revenue and Taxation Committee in its
analysis of SB 17 (Escutia), introduced in the 2005-06
legislative session, the initial example was a case of Kaiser
Steel, ownership of which was acquired by a consortium of
seven separate purchasers, none of whom received more than 50%
ownership, even though a 100% of the corporation had changed
hands. No "change of ownership" had occurred in that
transfer, and the property held by the company was not
reassessed, since no single party had acquired more than 50%
of the ownership. Similarly, in 2002, E&J Gallo bought Louis
M. Martini, but split the purchase among 12 Gallo family
members, thus preventing the underlying property from being
reassessed, at a property tax savings of some $700,000 per
year.
A fairly recent example of creative tax planning includes an
acquisition of Toys "R" Us, Inc., which operated as a public
company from 1978 until July 2005, by an investment group in a
$6.6. billion transaction. The acquisition encompassed all
worldwide operations of Toys "R" Us, Inc. According to the
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sponsor, upon the completion of this acquisition, each of the
investors - Bain Capital Partners LLC, Kohlberg Kravis,
Roberts & Co. (KKR), and Vornado Realty Trust - owns an equal
stake in Toys "R" Us. It has been reported that numerous
California properties owned by Toys "R" Us have not been
reassessed, presumably, because no investor owns more than 50%
ownership interest in the company. (CTRA Report, pp. 87-88).
Similarly, several California properties owned by the Hospital
Corporation of America (HCA) have not been reassessed even
though HCA was acquired by KKR, Bain Capital, Merrill Lynch
and the Frist family in a $31.6 billion buyout in 2006.
In another example, none of the Wachovia's real property located
in California has been reassessed to date, even though
Wachovia Corporation was acquired by Wells Fargo & Company in
an all-stock deal valued at $15.1 billion in December of 2008.
(Id., pp. 90-91). Apparently, Wachovia's real estate holdings
included more than 100 properties throughout the state.
Finally, very few of the 2,200 Washington Mutual (WaMu) Bank
properties have been reassessed to date, even though WaMu was
acquired in 2008 by JP Morgan Chase Manhattan, in a reported
$1.9 billion buyout. (Id., pp. 89-90).
The statutory provisions implementing Proposition 13 were
intended to ensure that, when an entity or person acquires a
business entity, a reassessment of the acquired entity's real
property is triggered, especially in cases when 100% of
ownership has changed. It is unlikely that the idea of
enabling multiple, affiliated purchasers of a corporation,
each acquiring less than a 50% ownership interest, to
completely avoid a reappraisal of the corporation's underlying
property was contemplated by the voters when approving
Proposition 13, or by the Legislature when enacting R&TC
Section 64 that sets forth the definition of "change in
ownership."
7)The Proposed Solution. As discussed, properties owned by
legal entities are taxed under a "separate entity" theory,
which means that, as long as the property is owned by the same
legal entity, that property would not be reassessed, even if
most or all of the ownership interests in the entity (i.e.,
stock in the corporation, partners in the partnership) had
changed ownership. According to the sponsor, this bill is
designed to close this obvious and egregious loophole in the
law by providing that, when 100% of ownership interests in a
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legal entity holding real property are sold or transferred in
a single transaction, the property must be reassessed, no
matter how many purchasers take ownership of the entity and
regardless of whether any one legal entity acquires more than
50% of the ownership interest. Under current law, only if a
particular transaction results in a change in control of a
legal entity (i.e. one legal entity or individual acquires
more than half of the ownership interest in the legal entity)
would the property owned by that legal entity be subject to
reassessment. Under this bill's provisions, a change in
ownership, most likely, would have been triggered in the case
of the Toys "R" Us acquisition as well as in the buyout of
HCA.
As pointed out by BOE in its analysis of this bill, AB 2492
would apply to any type of real property owned by a legal
entity, including single family homes, apartments, mobilehome
parks, agricultural property, family farms, and small
businesses. It would not be applicable to transfers of
ownership interests between a legal entity and individuals.
Thus, if four individuals purchase 100% of the ownership
interests equally in a legal entity in a single transaction,
there would be no "change in control" of the legal entity,
since no individual has obtained more than 50% of the
ownership. Furthermore, there will be no "change in
ownership" under this bill, and thus, real property owned by
the entity will not be reassessed.
Finally, although well intended, this bill would not preclude
businesses from structuring a transfer of ownership interest
in multiple transactions, or from ensuring that less than 100%
of the ownership interests are transferred. While the step
transaction doctrine may help assessors to "collapse the
steps" into a single transaction in some cases, the Committee
staff suggests that this bill be amended to provide what
constitutes "a single transaction" and specify the
circumstances under which multiple steps may be treated as a
single transaction.
8)What is a "Split Roll" ? The phrase "split roll" generally
refers to a system of taxation where various types of real
property are taxed according to different standards or at
different tax rates. The split is typically proposed between
residential property (or the subset of owner-occupied homes)
and all other property types. For instance, rather than
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taxing all property at the same rate, nonresidential property
could be taxed at a higher rate or at a higher percentage of
market value. This phrase is also used to describe any
legislation attempting to redefine "change in ownership" as it
applies to the purchase or transfer of ownership interests in
legal entities (i.e., stock or ownership shares in a
corporation or partnership) that own real property in a way
that would trigger more frequent reassessments to current
market value levels. While AB 2492 does not expressly propose
to create a different system of taxation for commercial
property, it attempts to redefine a "change in ownership"
event in the case of property held by legal entities.
9)Notification Requirement. As explained by BOE staff,
assessors discover changes in ownership of real property via
grant deeds or other documents that are recorded with the
county recorder. In addition, the county recorder must
provide the assessor with a copy of the transfer of ownership
document as soon as possible. However, no grant deed or other
document is recorded when a change in ownership of a legal
entity occurs, even if it triggers reassessment of underlying
real property. The BOE monitors changes in ownership and
changes in control of legal entities via the Legal Entity
Ownership Program (LEOP) and helps assessors to discover
unreported changes. But, ultimately, assessors depend on
legal entities to self-report these types of changes of
ownership.
Existing law requires a legal entity to file a change in
ownership statement with BOE within 45 days of whenever a
change in control or a change in ownership of a legal entity
occurs. If a legal entity fails to report and the failure is
discovered later on, then an escape assessment will be made
for every tax year that the entity failed to file the change
in ownership statement. There is no statute of limitations
that would apply to those escape assessments. The penalty for
failure to file a change in ownership statement upon written
request by the BOE is 10% of the new base year value resulting
from the transfer, or 10% of the current year's taxes on that
property if no change in control or change in ownership
occurred.
AB 2492 requires BOE to notify assessors when a change in
ownership of a legal entity has occurred pursuant to this
bill.
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10)Related Legislation . BOE notes that, in recent years,
numerous bills have been introduced to require annual
reassessment of nonresidential property to its current market
value via constitutional amendment, increase the tax rate on
nonresidential property, or modify the change in ownership
definitions for legal entities (which generally own
nonresidential property). The following BOE table lists some
of those measures:
-------------------------------------------------------------------
|Year|Bill |Summary |
| | | |
|----+-------------+------------------------------------------------|
|2005|SB |Change in Ownership Definitions. Provides that |
| |17(Escutia) |a change in ownership occurs when more than 50% |
| | |of the ownership interests in a legal entity |
| | |(excluding publicly traded companies) are |
| | |transferred to one or more persons or entities |
| | |during a calendar year. |
|----+-------------+------------------------------------------------|
|2003|SB |Change in Ownership Definitions. Redefine |
| |17(Escutia) |change in ownership for nonresidential |
| | |commercial and industrial property. |
| | |(Legislative intent) |
|----+-------------+------------------------------------------------|
|2003|ACA 16 |Annual Reassessment. Annual reassessment of |
| |(Hancock) |nonresidential, nonagricultural property. |
|----+-------------+------------------------------------------------|
|2003|SBx1 3 |Change in Ownership Definitions. Redefine |
| |(Escutia) |change in ownership for nonresidential |
| | |commercial and industrial property. |
| | |(Legislative intent) |
|----+-------------+------------------------------------------------|
|2002|SB 1662 |Change in Ownership Definitions. Reassessment |
| |(Peace) |of nonresidential property when cumulatively |
| | |more than 50% of the ownership has been |
| | |transferred. Broaden the state and local sales |
| | |and use tax base and reduce both the state and |
| | |local sales and use tax rate. (Legislative |
| | |intent) |
|----+-------------+------------------------------------------------|
|2001|AB 1013 |Change in Ownership Definitions. Reassessment |
| |(Leonard) |of property owned by a legal entity when more |
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| | |than 50% of the ownership shares transfer. |
|----+-------------+------------------------------------------------|
|2000|AB 2288 |Change in Ownership Definitions. Reassessment |
| |(Dutra) |of property owned by legal entity once every |
| | |three years - Rebuttable presumption of change |
| | |in ownership. Possible income tax credit to |
| | |homeowners based on fair market value of homes |
| | |from additional revenue. Reduce the sales and |
| | |use tax rate by 0.25%. |
|----+-------------+------------------------------------------------|
|1991|SB 82 (Kopp) |Change in Ownership Definitions. Reassessment |
| | |of legal entities when cumulatively more than |
| | |50% of the ownership has been transferred. |
-------------------------------------------------------------------
None of the bills listed above ever reached the Governor's desk.
REGISTERED SUPPORT / OPPOSITION :
Support
Bay Area Parent Leadership Action Network
California Tax Reform Association (sponsor)
Contra Costa Interfaith Supporting Community Organization
California Teachers Association
California Immigrant Policy Center
California for Justice
California Federation of Teachers, AFT, AFL-CIO
California Labor Federation, AFL-CIO
California School Employees Association, AFL-CIO
California Partnership
California Pan-Ethnic Health Network (CPEHN)
Center on Policy Initiatives
Commission on the Status of Women
Community Asset Development Re-defining Education (CADRE)
Contra Costa Democratic Central Committee
Eviction Defense Network
InnerCity Struggle
LAANE
Mission Economic Development Agency
National Association of Social Workers, California Chapter
Public Advocates
The Richmond Progressive Alliance
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San Mateo County Central Labor Council
San Diego and Imperial Counties Labor Council
Service Employees International Union (SEIU) Local 1000
Teamsters Local Union No. 856
The American Federation of Teachers, Local 1931
The American Federation of State, County and Municipal Employees
(AFSCME)
The Utility Reform Network (TURN)
The "Having Our Say" Coalition
UFCW 101
Western Center on Law and Poverty
Opposition
Pacific Life Insurance Company
Fresno Chamber Members (22 individuals)
California Taxpayers Association on behalf of:
AGC of California
Air Logistics Corporation
Allied Retail Partners
American Council of Engineering Companies of California
Apartment Association of Greater Los
Angeles
Association of California Life and Health
Insurance Companies
BayBio
BOMA, Inland Empire
BOMA, Oakland/East Bay
BOMA, Orange County
BOMA, Greater Los Angeles
BOMA, Sacramento
BOMA, San Diego
BOMA, San Francisco
BOMA, Silicon Valley
Borelli Investment Company
Building Owners and Managers Association of California
Burnham USA Equities Inc.
California Aerospace Technology Association
California Apartment Association
California Association of Realtors
California Bankers Association
California Building Industry Association
California Business Properties Association
California Business Roundtable
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California Chamber of Commerce
California Chapter of the American Fence Association
California Fence Contractors Association
California Forestry Association
California Grocers Association
California Healthcare Institute
California Hotel & Lodging Association
California Independent Grocers Association
California Independent Petroleum Association
California Land Title Association
California Manufacturers and Technology Association
California Mortgage Bankers Association
California Restaurant Association
California Retailers Association
Calmat Company
CB Richard Ellis
CDC Commercial
Chambers of Commerce Alliance of Ventura
& Santa Barbara Counties
Cindy Delgado Wheeler, State Farm Agent
Independent Contractor
Commercial Retail Associates
Costco
DMS Facility Services
Ellis Partners
Engineering Contractors Association
Flasher/Barricade Association
Florida Rock Products, Inc.
Greater Fresno Area Chamber of Commerce
Howard Jarvis Taxpayers Association
International Council of Shopping Centers
JC Penney Corporation, Inc.
J.F. Shea Company
JG Construction
Kilroy Realty Corporation
LA FITNESS International
LBA Realty
Lee & Associates Commercial Real Estate Services
Lockheed Martin Space Systems Company
Los Angeles Chamber of Commerce
Los Angeles County Business Federation Board
LS Realty Group
Macerich
Macy's Inc.
Marin Builders Association
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Milpitas Chamber of Commerce
Nadel Architects
NAIOP of California, the Commercial Real Estate Development
Association
Napa Chamber of Commerce
National Association of Real Estate Investment Trusts
National Federation of Independent Business
NorthMarq Real Estate Services
Orange County Business Council
Palm Desert Chamber of Commerce
Palomar Transit Mix, Inc.
PIER 39
PM Realty Group
Precision Gymnastics, Inc.
Proseco, Inc.
PS Business Parks, Inc.
Public Storage
Raytheon
Red Mountain Group
Retail Industry Leaders Association
Safeway Inc.
San Diego East County Chamber of Commerce
San Fernando Valley Chamber
Santa Clara Chamber of Commerce and Convention-Visitors Bureau
Seawright Custom Precast, Inc.
Silicon Valley Leadership Group
Simi Valley Chamber of Commerce
Small Business Action Committee
Solar Turbines (A Caterpillar Company)
Sunstone Hotel Investors, Inc.
Target
TechAmerica
TechNet
The Boeing Company
The Home Depot
The Kenney Company
Triangle Rock Products, Inc.
Valley Industry & Commerce Association (VICA)
Val Rock, Inc.
Vulcan Lands Company
Vulcan Materials Company
Western States Petroleum Association
Westlake Realty Group
Wine Institute
W.L. Butler Construction
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Analysis Prepared by : Oksana Jaffe / REV. & TAX. / (916)
319-2098