BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 874
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          Date of Hearing:  July 2, 2012

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Henry T. Perea, Chair
                   SB 874 (Hancock) - As Amended:  January 4, 2012
           
           Majority vote. 
           
          SENATE VOTE  :  35-0
           
          SUBJECT  :  School and community college districts:  parcel taxes: 
           exemptions.

           SUMMARY  :  Authorizes school districts to exempt disabled persons 
          from special taxes.  Specifically,  this bill  expands an existing 
          exemption from "qualified special taxes" that may be imposed by 
          school districts to include any persons receiving Social 
          Security Disability Insurance (SSDI) regardless of age, as 
          provided.

           EXISTING LAW  :

          1)Prohibits school districts from imposing general taxes, but 
            allows school districts, community college districts, and 
            county offices of education to issue bonded indebtedness for 
            school facilities with 55% approval.  (Proposition 39, 2000).  


          2)Authorizes school districts to impose qualified special taxes, 
            in accordance with specified procedures, including the 
            approval of two-thirds of the voters in the district.

          3)Provides that "qualified special taxes" must apply uniformly 
            to all taxpayers or all real property within the school 
            district and do not include special taxes imposed on a 
            particular class of property or taxpayers.  

          4)Authorizes a school district to exempt from a "qualified 
            special tax" a person 65 years of age or older or persons 
            receiving Supplemental Security Income for a disability, 
            regardless of age.
             
           FISCAL EFFECT  :  Unknown, but Committee staff estimates a 
          possible revenue gain to local school districts. 









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           COMMENTS  :   

           1)Author's Statement  .  The author states that, "SB 874 gives 
            school districts options when crafting local taxes measures by 
            allowing them to exempt certain property owners from a parcel 
            tax.  Individuals who are disabled and receiving SSFI may not 
            be able to pay the tax because their disability prevents or 
            limits their ability to work."

           2)Arguments in Support  .  The proponents state that SB 874 would 
            "help correct an inequity in the current law" by expanding the 
            current exemption to include persons receiving SSDI.  The 
            proponents argue that SSDI recipients are "among California's 
            neediest citizens," who live on "fixed incomes and are already 
            impacted by benefit reductions due to state budget cuts."  The 
            proponents believe that exempting SSDI recipients "increases 
            the likelihood that parcel taxes will be approved, thereby 
            providing flexible ways of raising revenues upon affirmation 
            by local voters."  

           3)Arguments in Opposition  .  The opponents argue that SB 874 "is 
            deceptive" and, while "superficially beneficial to seniors and 
            the disabled, in application, it is a bait and switch scheme." 
             The opponents claim that because seniors and the disabled 
            "would have to opt-out annually - something that most will 
            forget to do - the real objective of this measure is to create 
            the appearance of an exception as a means for additional votes 
            in favor of tax increases."

           4)"Qualified Special Taxes":  Background.   In 1978, Proposition 
            13 limited both the tax rates and assessments, thus 
            significantly reducing property tax revenues.  It also 
            eliminated the ability of school districts to levy an 
            incremental ad valorem tax on real property.  However, school 
            districts still have limited authority to generate local 
            revenues from qualified special taxes, as long as the special 
            tax applies uniformly to all taxpayers (other than persons 
            over the age of 65 or persons receiving Supplemental Security 
            Income (SSI)) or real property within the district.  While 
            Proposition 13 did not define the term "special tax", the 
            courts, over time, have opined that a tax is a "special tax" 
            whenever expenditure of its revenues is limited to specific 
            purposes, i.e. the proceeds of the tax are earmarked or 
            dedicated in some manner to a specific project or projects.  
            In contrast, a tax is a "general tax" only when its revenues 








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            are placed into the General Fund and are available for 
            expenditure for any and all governmental purposes.  �Bay Area 
            Cellular Telephone Co. v. City of Union City (2008) 162 Cal. 
            App.4th 686; Howard Jarvis Taxpayers Assn. v. City of 
            Roseville (2003) 106 Cal.App.4th 1178].  School districts and 
            special districts are prohibited from imposing general taxes 
            (Proposition 218) and thus, by definition, any tax levied by a 
            school district or community school district is considered to 
            be a special tax subject to a two-thirds voter approval.  
            Furthermore, school districts are not allowed to impose a 
            special tax that is imposed on a particular class of property 
            or taxpayers.  Therefore, thus far, school districts have only 
            imposed "qualified special taxes", under Government Code 
            Section 50079, in the form of a parcel tax.  

           5)Parcel Taxes.   A parcel tax is a flat fee imposed by a city, 
            county, or special district on each parcel, residential as 
            well as commercial, rather than on the assessed value of 
            property located within the local entity's jurisdiction.  
            Because the same dollar amount of tax is assessed on each 
            parcel of property, whether the parcel is one acre or 100 
            acres, parcel taxes are generally regressive, which means 
            owners of smaller parcels of land pay a larger percentage of 
            tax as compared to owners of larger parcels of land.  Some 
            districts levy a rate at a fixed amount per square foot of 
            taxable land, and many include an annual inflation adjustment. 
             
             
             Parcel taxes are flexible ways of raising revenues at the 
            local level, but are subject to certain requirements.  Parcel 
            tax elections must be held on "established election dates", 
            which means in March, April, or November of an even-numbered 
            year, or March, June, or November in an odd-numbered year.  
            Existing law does not prescribe a maximum rate of tax nor does 
            it limit the period within which the qualified special tax may 
            be imposed.   Therefore, the rate of tax varies significantly 
            among different school districts.  Existing law does not limit 
            how the special tax proceeds may be spent, and therefore, a 
            local school board can specify in the ballot measure how the 
            funds will be used.  Generally, local parcel taxes provide 
            secure funding for teacher salaries, books, materials and 
            supplies, computers, and art, music and sports programs.

            According to EdSource, between 1983 through November 2010, 
            voters approved 289 parcel taxes in 542 elections, with 92% of 








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            proposals receiving at least a majority vote from the 
            electorate during that time.  Districts have increasingly 
            turned to parcel taxes in recent years as a result of fiscal 
            stress:  In 2010, 38 districts placed parcel taxes on the 
            ballot, compared to 31 in 2009, and 13 in 2006.  The median 
            district levying a parcel tax had about 3,180 students of whom 
            15% qualified for free/reduced-price meals and 9% were English 
            learners.  
            Interestingly, school districts in some areas of the state 
            seek to levy parcel taxes more so than other areas.  According 
            to EdSource, only seven districts in Southern California 
            imposed the tax, but 66 did in the San Francisco Bay Area.  
            Districts imposing the tax generally serve fewer low-income 
            students than the typical California school district, and are 
            disproportionately smaller, with 66 (80%) of them serving 
            fewer than 10,000 students. 

            In 2006, the California voters rejected Proposition 88 that 
            would have amended the California Constitution to levy an 
            annual $50 real property tax on most parcels with the funds 
            allocated to specified K-12 education programs.   

           6)The Current Exemption:  Who Qualifies?   School districts are 
            currently authorized to exempt persons over the age of 65 from 
            qualified special taxes, as well as persons receiving 
            Supplemental Security Income (SSI) for a disability, 
            regardless of age.  The SSI program is a federal income 
            program administered by the Social Security Administration 
            (SSA).  The program is funded by general federal revenues and 
            provides monthly cash benefits to low-income individuals who 
            are blind, disabled or 65 years of age or older.  
                
            7)The Proposed Exemption  .  SB 874 authorizes school districts to 
            exempt persons receiving SSDI when the district levies a 
            qualified special tax.  The SSDI program is administered by 
            the SSA and is financed with federal payroll taxes.  It 
            provides benefits to disabled persons whose disability serves 
            as a barrier to employment.  To be eligible for SSDI, the 
            individual must be unable to perform substantial work activity 
            because of a severe physical or mental impairment, which has 
            lasted or is expected to last at least 12 consecutive months, 
            or to result in death.  In addition, the individual must earn 
            sufficient credits based on taxable work to be "insured" for 
            Social Security purposes.  SSDI recipients are eligible for 
            Medicare after receiving disability benefits for two years.  








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            However, unlike the SSI program, the SSDI eligibility is not 
            restricted by an individual's income or assets.  

          The exemption proposed by this bill is permissive rather than 
            mandatory, which allows the school district to consider the 
            need for, and impact of, an exemption from special taxes 
            imposed.  By its terms, this bill does not limit the exemption 
            to  homeowners  (taxpayers) that qualify or specify that the 
            person qualifying for the exemption must also live in the 
            property rather than own it as an investment.  It is unclear 
            whether the exemption is available if the property is owned by 
            more than one person and only one person qualifies for the 
            exemption.  However, the exemption granted under this bill 
            merely expands a current exemption, so committee staff expects 
            that the new exemption will be applied consistent with current 
            law.   

           8)School Districts vs. Community College Districts  .  The current 
            version of SB 874 would only apply to school districts, while 
            one of the previous versions of this bill would have also 
            authorized community college districts to exempt person over 
            the age of 65 as well as SSI and SSDI recipients from a 
            qualified special tax.  Under existing law, community college 
            districts are not allowed to exempt any person from qualified 
            special taxes. 

           9)Is the Proposed Exemption Warranted  ?  As a special tax, a 
            parcel tax levied by a school district requires approval at an 
            election of at least two-thirds of the qualified electors of 
            such district.  Courts have interpreted the phrase "qualified 
            electors of such district" to mean the registered voters 
            voting in the election concerning the proposed tax.  �Neilson 
            v. City of California City (2005) 133 Cal. App.4th 1296, 
            1312].  Generally, nonresident landowners are not registered 
            voters and are not included among the voters voting on the 
            proposed parcel tax.  On the other hand, some registered 
            voters who do not own land within the district's boundaries 
            are able to vote on the parcel tax even though they will not 
            be paying that tax (at least not directly).  In addition, 
            districts may exempt taxpayers over the age of 65 and SSI 
            recipients, thereby creating another class of voters who do 
            not bear the incidence of the tax.  By exempting an additional 
            class of taxpayers - SSDI recipients, school districts may be 
            forced to impose a higher parcel tax for non-exempt taxpayers 
            because of the diminished base, all else being equal.  The 








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            Committee may wish to consider whether authorizing school 
            districts to exempt more taxpayers from new parcel taxes is 
            equitable when many voters already do not bear the cost of tax 
            and some of those who bear the cost are not eligible to vote. 

           10)Related Legislation  . 

          AB 385 (Lieber), Chapter 41, Statutes of 2006, allowed school 
            districts the authority to exempt SSI recipients from 
            qualified special taxes.  

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          Community College League of California
          Disability Rights California
           
            Opposition 
           
          Howard Jarvis Taxpayers Association

           Analysis Prepared by  :  Oksana Jaffe / REV. & TAX. / (916) 
          319-2098