BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2643
                                                                  Page  1

          Date of Hearing:  May 2, 2012

                       ASSEMBLY COMMITTEE ON LOCAL GOVERNMENT
                                Cameron Smyth, Chair
                      AB 2643 (Ma) - As Amended:  April 24, 2012
           
          SUBJECT  :  Property taxation.

           SUMMARY  :  Makes several changes to the statutes related to 
          property tax collection.  Specifically,  this bill  :  

          1)Authorizes the tax collector, when the amount of property 
            taxes paid exceeds the amount due as of the date and time the 
            payment is received, to process the refund without sending a 
            required notice and without the taxpayer filing a claim for 
            refund, if the tax collector establishes that a refund is due 
            to the taxpayer.

          2)Deletes the exception for the return of replicated property 
            tax payments, for purposes of allowing the tax collector to 
            apply any refund due a taxpayer, or the taxpayer's agent, to 
            any delinquent taxes due for the same property for which the 
            same taxpayer, or his or her agent, is liable, thereby 
            applying the provisions authorizing the tax collector to apply 
            any refund to any delinquent taxes.

          3)Limits penalty relief, for cases in which a taxpayer has 
            failed to pay taxes on an assessment that is the subject of a 
            pending informal review due to a decline in value as a result 
            of damage, destruction, depreciation, obsolescence, removal of 
            property, or other factors causing a decline in value, to the 
            difference between the county assessor's final determination 
            of value and the value on the assessment roll for the fiscal 
            year covered by the application.

          4)Restricts the penalty relief specified in 3) above to those 
            properties upon which an application for an informal review is 
            pending before the county assessor on the effective date of 
            the bill's implementation, or in situations where those 
            applications for an informal review are filed with the county 
            board after the date of the bill's implementation.

          5)Extends, for purposes of calculating the interest on property 
            tax refunds, the time period the county treasurer has to 
            advise the Controller of the county pool apportioned rate and 








                                                                  AB 2643
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            of computations made in deriving that rate from 60 to 90 days.

           EXISTING LAW  :

          1)Requires, when the amount of property taxes paid exceeds the 
            amount due by more than $10, the tax collector to send notice 
            of the overpayment to the taxpayer, and provides that the 
            notice must be mailed to the taxpayer's last known address and 
            state the amount of overpayment and that a refund claim may be 
            filed, as specified.

          2)Allows the tax collector to apply any refund due a taxpayer, 
            or the taxpayer's agent, to any delinquent taxes due on the 
            same property for which the same taxpayer or his or her agent 
            is liable, except as specified for the return of replicated 
            property tax payments.

          3)Limits, in the case in which a taxpayer has failed to pay 
            taxes on an assessment that is the subject of a pending 
            assessment appeal, as provided, the amount of penalty relief 
            to the difference between the final determination of value by 
            the county board, as defined, and the value on the assessment 
            roll for the fiscal year covered by the application. 

          4)Requires the county board to provide a specified notice to 
            taxpayers impacted by the penalty provisions.

          5)Requires the payment of interest on property tax refunds at 
            the greater of 3% per annum or the county pool apportioned 
            rate.  

          6)Requires the county treasurer to advise the State Controller 
            of the county pool apportioned rate and of computations made 
            in deriving that rate, no later than 60 days after the end of 
            that fiscal year.

           FISCAL EFFECT  :  None

           COMMENTS  :   

          1)AB 2643 is sponsored by the California Association of County 
            Treasurers and Tax Collectors (CACTTC) and makes several 
            changes to the laws related to property tax collection.   
            First, the bill authorizes treasurers and tax collectors to 
            issue a refund when one is due to a taxpayer because the 








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            amount of taxes paid exceeds the amount due.  Current law 
            requires treasurers and tax collectors to send a notice to 
            taxpayers who must then file a claim to receive the 
            overpayment.  The bill deletes the provisions in current law 
            that requires treasurers and tax collectors to notify 
            taxpayers of overpayment.

            Second, the bill extends the time county treasurers have to 
            calculate the pool rate and report it to the State Controller 
            from 60 days to 90 days after the end of the fiscal year.  
            Current law requires the payment of interest on property tax 
            refunds at the greater of 3% per annum or the county pool 
            apportioned rate.

            Lastly the bill limits penalty relief, for cases in which a 
            taxpayer has failed to pay taxes on an assessment that is the 
            subject of a pending informal review due to a decline in value 
            as a result of the damage, destruction, depreciation, 
            obsolescence, removal of property, or other facts causing a 
            decline in value, to the difference between the county 
            assessor's final determination of value and the value on the 
            assessment roll for that fiscal year.  The bill provides that 
            penalty relief only applies to those properties for which an 
            application for an informal review is pending before the 
            county assessor on or after the effective date of the bill's 
            implementation.

          2)Current law limits penalty relief, for cases in which a 
            taxpayer has failed to pay taxes on an assessment that is the 
            subject of a pending assessment appeal, to the difference 
            between the county board of supervisor's final determination 
            of value and the value on the assessment roll for that fiscal 
            year.  Current law requires the county board of supervisors to 
            provide mailed notice to each taxpayer upon an application for 
            reduction in assessment with the county board if that taxpayer 
            will be impacted by the penalty provisions, and also requires 
            the board of supervisors, with the approval of the county's 
            tax collector and auditor, to adopt an ordinance that approves 
            this section of law dealing with limiting penalty relief.  The 
            penalty under these provisions is 10% of the tax due.

          3)Under current law, the penalty calculations are different 
            depending upon whether the assessor or the assessment appeals 
            board lowers the value.  This bill creates consistency in the 
            penalty calculations by making it the same for both types of 








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            valuation decreases.  The sponsor indicates that this 
            provision will remove the incentive for taxpayers to pay tax 
            bills late when a value reduction is pending from the 
            assessor.

          4)Section 1 of this bill contains provisions that allow the 
            county tax collector to process a property tax refund without 
            sending the notice of overpayment to the taxpayer that is 
            required under current law.  A similar provision was included 
            in early versions of SB 948 (Committee on Governance and 
            Finance) of 2011, but was removed when opposition to that 
            particular provision was voiced.

            The opposition raised the concern that by deleting the tax 
            collector's ministerial duty to give notice to taxpayers of 
            the right to make a timely refund claim, the net effect would 
            be to deprive taxpayers of their constitutional right to due 
            process notice.

            The Committee may wish to ask the author and sponsor to 
            discuss this issue further and determine whether the language 
            in Section 1 of the bill deprives taxpayers of notice of 
            overpayment, as well as the legal implications of changing 
            this statute on a going-forward basis for taxpayers.

           5)Support arguments  :  Supporters argue that this bill clarifies 
            the statutes related to property tax collection and 
            overpayment, penalty relief, and gives county treasurers a 
            longer period of time to calculate the pool rate and report it 
            to the State Controller.

             Opposition arguments  :  One might argue that this bill deprives 
            a taxpayer of the right to be notified when property tax 
            overpayment occurs.

          6)This bill is double-referred to the Committee on Revenue and 
            Taxation.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Association of County Treasurers and Tax Collectors 
          (CACTTC) �SPONSOR]
          California State Association of Counties








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           Opposition 
           
          Law Offices of Robert A. Pool
           
          Analysis Prepared by  :    Debbie Michel / L. GOV. / (916) 
          319-3958