BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                  SB 1250|
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                                 THIRD READING


          Bill No:  SB 1250
          Author:   Ducheny (D)
          Amended:  6/2/10
          Vote:     21

           
           SENATE REVENUE & TAXATION COMMITTEE  :  5-0, 4/14/10
          AYES:  Wolk, Walters, Alquist, Ashburn, Padilla

           SENATE APPROPRIATIONS COMMITTEE  :  10-0, 5/27/10
          AYES:  Kehoe, Alquist, Corbett, Denham, Leno, Price,  
            Walters, Wolk, Wyland, Yee
          NO VOTE RECORDED:  Cox


           SUBJECT  :    Property tax:  military housing

           SOURCE  :     County of San Diego


           DIGEST  :    This bill expands the property tax exemption  
          currently provided to private operators of family housing  
          on military bases to include non-family housing.  

           ANALYSIS  :    Current law generally prohibits the taxation  
          of property owned by the federal government and other  
          public land, but imposes a "possessory interest" tax on  
          federally-owned property used by a private interest, such  
          as a private lease of public land, if the private use meets  
          three tests of independence, durability, and exclusivity.   
          Under the federal Military Housing Privatization  
          Initiative, which was enacted in 1996, the federal  
          government began privatizing military housing.  The  
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          authorization was initially limited to agreements between  
          the military and private developers for ownership,  
          maintenance, and operation of family housing via a 50-year  
          lease.  In response, the Legislature enacted SB 451  
          (Ducheny), Chapter 853, Statutes of 2004, which specified  
          that a private developer's interest in military family  
          housing is not "independent" for purposes of imposing a  
          possessory interest tax, and therefore exempt from the  
          property tax.  This exemption does not apply to  
          unaccompanied housing for single enlisted service members.

          In 2003, Congress authorized the Department of the Navy to  
          undertake up to three pilot projects for the privatization  
          of unaccompanied housing, such as bachelor enlisted  
          quarters, barracks, and dormitories.  The Navy selected a  
          private developer for a public-private venture to provide  
          housing for single military personnel at Naval Station San  
          Diego.  This project, Pacific Beacon LLC, privatized 258  
          units of Navy-owned unaccompanied housing units and  
          provides for the construction of 941 apartments at Naval  
          Station San Diego, which the LLC will own, operate, and  
          manage for 50 years.  Construction broke ground in January  
          2007 and was substantially completed in March 2009.  

          This bill specifies that there is no independent possession  
          of land or improvements that are due to a contract that  
          includes a lease for the development of housing solely for  
          active duty military personnel, or their dependents, or  
          both, thereby exempting both family and unaccompanied  
          housing projects from property tax.  

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes    
          Local:  No

          The Senate Appropriations Committee staff notes that San  
          Diego County has asked the Board of Equalization (BOE)  
          for a legal opinion of whether the Pacific Beacon project  
          constitutes a possessory interest under existing law.   
          BOE recently opined that the arrangement between Pacific  
          Beacon and the government does not result in the creation  
          of a taxable possessory interest, so any assessments on  
          the property will be cancelled and the project will be  
          exempt from future property taxation.  However, to the  
          extent this bill exempts future "bachelor housing"  







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          developments on military bases from property tax, this  
          bill creates future General Fund impacts.

           SUPPORT  :   (Verified  6/1/10)

          County of San Diego (source)
          Clark Realty Capitol
          San Diego County Assessor
          San Diego Regional Chamber of Commerce


          DLW:mw  6/2/10   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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