BILL ANALYSIS                                                                                                                                                                                                    �



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          Date of Hearing:  July 2, 2012

                     ASSEMBLY COMMITTEE ON REVENUE AND TAXATION
                                Henry T. Perea, Chair
                     SB 1492 (Leno) - As Amended:  April 9, 2012

          Majority vote.  Fiscal committee.

           SENATE VOTE  :  22-16
           
          SUBJECT  :  Voter-approved local assessment: vehicles

           SUMMARY  :  Authorizes the City and County of San Francisco (City 
          and County) to impose a voter-approved local assessment (vehicle 
          assessment) on specified vehicles.  Specifically,  this bill  :   

          1)Authorizes the City and County board of supervisors, by 
            ordinance, to impose a vehicle assessment for general revenue 
            purposes, if all of the following conditions are satisfied:  

             a)   The ordinance complies with both of the following:

               i)     Specified requirements set forth in this bill; and

               ii)    The requirements of existing law pertaining to vote 
                 thresholds that must be attained before a local 
                 government or district can impose either special or 
                 general taxes.

             b)   The ordinance is approved by a two-thirds vote of the 
               board of supervisors;

             c)   The ordinance proposing the "vehicle assessment" is 
               approved by a majority vote of the voters voting on the 
               ordinance; and,  

             d)   The board of supervisors transmits to the Department of 
               Motor Vehicles (DMV) and the Franchise Tax Board (FTB) a 
               certified copy of the ordinance imposing the vehicle 
               assessment immediately after the results of the election by 
               the voters are certified.

             e)   The proposed assessment does not create different 
               classes of vehicles (whether by type, size, passenger 
               capacity, value or cost, fuel consumption or any other 








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               characteristic) for differential taxation (whether by rate, 
               method, assessment ratio, or any other means), except for 
               specified vehicle license fee exemptions contained in 
               current law.  

          2)Requires an ordinance imposing a vehicle assessment to include 
            the following specific provisions stating that:  

             a)   The vehicle assessment is to be imposed on residents of 
               the City and County, for the privilege of operating a 
               vehicle or trailer coach on public highways in the City and 
               County;

             b)   The annual amount of the vehicle assessment is to be set 
               as the difference between 2% of the market value of a 
               vehicle or trailer and the current vehicle license fee 
               (VLF), including any offset to that rate, and cannot exceed 
               2% of a vehicle's market value;

             c)   Any adjustment to the rate required to be made because 
               of a change in the rate of the  VLF, or any offset to that 
               rate, may not take effect until the first day of the fiscal 
               year (FY) following the one in which the change became 
               operative; 

             d)   The assessment will begin to be imposed if the election 
               in which the ordinance receives voter approval occurs 
               between:

               i)     January 1 and June 30, on January 1 following that 
                 election; or

               ii)    July 1 and December 31, on July 1 following that 
                 election.

             e)   Provisions identical to those contained in the state VLF 
               Law, insofar as they relate to VLFs and are applicable, 
               except that the name of the City and County as the taxing 
               agency shall be substituted for that of the state;

             f)   All amendments, subsequent to the effective date of the 
               vehicle assessment ordinance, to the VLF Law and not 
               inconsistent with this bill shall automatically be 
               incorporated into the ordinance; and









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             g)   The City and County, is required to contract with the 
               DMV for the administration and collection of the vehicle 
               assessment.  The contract must contain provisions in 
               substance as follows:

               i)     A requirement that DMV perform all functions 
                 incident to the administration and collection of the 
                 vehicle assessment;

               ii)    A provision specifying the manner in which refunds 
                 to a licensee pursuant to Revenue and Taxation Code 
                 (R&TC) Part 5 (commencing with Section 10701), as 
                 incorporated in the vehicle assessment ordinance, will be 
                 made and administered; and 

               iii)   A provision that requires the City and County to pay 
                 DMV for the initial setup and programming costs 
                 identified by the DMV. 

          3)Provides that a voter-approved ordinance imposing a vehicle 
            assessment, if consistent with conditions set forth in this 
            bill, that was approved by the board of supervisors and the 
            voters prior to this bill becoming effective is enforceable, 
            if both of the following apply:

             a)   The assessment is not imposed until at least 90 days 
               after the effective date of this bill; and 

             b)   The board of supervisors ratifies its adoption of the 
               ordinance after the effective date of this bill and prior 
               to the first levy of the vehicle assessment imposed 
               pursuant to the approval of the ordinance.  

          4)Requires DMV to do all of the following in administering a 
            vehicle assessment:

             a)   Collect the voter-approved vehicle assessment pursuant 
               to a contract with the City and County;

             b)   Deduct its costs in administering the vehicle assessment 
               from the collected assessments;

             c)   Transmit to the State Controller for deposit in the 
               General Fund (GF) the amount necessary to compensate the GF 
               for the loss incurred in the prior year as the result of 








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               the deductions taken by the taxpayers for the vehicle 
               assessments under the Personal Income Tax (PIT) Law �R&TC 
               Part 10 (commencing with Section 17001)] and the 
               Corporation Tax (CT) Law �R&TC Part 11 (commencing with 
               Section 23001)]; 

             d)   Transmit to the City and County remaining revenues 
               derived from the assessments, as promptly as feasible; and 

             e)   Develop, in conjunction with the FTB, a reporting 
               process that would enable DMV to report to the FTB, in a 
               timely manner, the data necessary for the FTB to prepare 
               the estimate of revenue loss attributable to taxpayer 
               deductions for the vehicle assessments under the PIT and CT 
               Laws.  

          5)States that this bill's provisions should not be construed as 
            supplanting any moneys that the state apportions to the City 
            and County, as specified. 

          6)Provides that, if the City and County imposes a vehicle 
            assessment and experiences a reduction in revenue because of 
            an increase in the VLF rate, including any offset to that 
            rate, the state will not reimburse the City and County for 
            that loss in revenue.  

          7)Requires the FTB to report to DMV, on or before January 1 of 
            the second year after the assessment is imposed, and annually 
            thereafter, an estimate of the total amount of revenue lost to 
            the state in the prior year resulting from deductions taken 
            under the PIT and CT Laws for taxes paid or incurred as a 
            result of the vehicle assessment having been imposed. 

          8)States that this act shall be known, and citied, as the Local 
            Assessment Act. 

          9)Defines several terms related to this bill's provisions. 

          10)States that the Legislature finds and declares that a special 
            law is necessary because numerous groups in the City and 
            County have requested that authorization be granted for such 
            an assessment in that City and County. 

           EXISTING LAW  :









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          1)Imposes a VLF, which is in lieu of a personal property tax on 
            California motor vehicles, at a rate based on the taxable 
            value of the vehicle.  The taxable value of a vehicle is 
            established by the purchase price of the vehicle, depreciated 
            annually according to a statutory schedule.  Prior to May 19, 
            2009, the VLF tax rate was set at 0.65% of the value of a 
            vehicle.  For vehicles registered between May 19, 2009 and 
            June 30, 2010, the VLF rate was temporarily increased to 1.15% 
            �ABx3 3 (Evans), Chapter 18, Statutes of 2009].  The revenues 
            from the portion of the rate increase from 0.65% to 1% were 
            deposited in the State GF, whereas revenues from the 
            additional increase of 0.15% were dedicated to specific local 
            public safety programs. 

          2)Provides that VLFs collected by the state are allocated to 
            cities, counties, and cities and counties, less the costs of 
            collection and any refunds.  �Article XI, Section 15, 
            California Constitution].

          3)Authorizes cities, counties, and special districts to impose a 
            general tax for general governmental purposes with the 
            approval of a majority of the voters.

          4)Authorizes cities, counties, and special districts to impose a 
            special tax for specified purposes with the approval of 
            two-thirds of the voters.

          5)Allows taxpayers to deduct the VLF amount on their state 
            income tax returns as an itemized deduction.  The VLF is also 
            deductible for federal income tax purposes.

           FISCAL EFFECT  :  The FTB staff estimates that this bill will 
          result in an annual GF revenue loss of $2.7 million in the 
          fiscal year (FY) 2014-15, $1.6 million in FY 2015-16, and $0.2 
          million in FY 2016-17.  These estimates are based on the 
          assumption that the City and County would begin imposing the 
          maximum local VLF on July 1, 2014 and that the proposed vehicle 
          assessment would be deducted beginning with the 2014 tax 
          returns. 

           COMMENTS  :    

          1)Purpose of this Bill.   According to the author, the VLF is one 
            of the largest sources of general-purpose tax revenues for 
            California's counties.  These revenues fund vital programs, 








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            including public safety, public health, social services, fire 
            protection, public works, and cultural activities.  As noted 
            by the author, SB 1492 would grant the people of the City and 
            County the right to choose whether to levy a fee upon 
            themselves to fund vital services, giving county voters a 
            viable alternative to cutting services.  SB 1492 allows for 
            voter determination in these severely challenged fiscal times. 


           2)Proponents.   The proponents of this bill state that SB 1492 
            would allow the voters of the City and County to levy a fee 
            upon themselves to fund local vital services.  Furthermore, 
            this bill provides a viable alternative to cutting services at 
            a time when new funding is limited.  It would create a tool 
            for the City and County to continue to provide the level of 
            public services residents demand.

           3)Opponents.   The opponents of this bill argue that with new 
            vehicle sales down at least 33% from those in the last decade, 
            gasoline prices exceeding $4 per gallon, and high unemployment 
            in our current poor economic climate, there continues to be no 
            reason to further increase the cost of vehicle ownership in 
            California.  According to the opposition, California motorists 
            are overtaxed compared to the rest of the nation. 

           4)Local taxes  .  Constitutional requirements for voter approval 
            of local taxes were initiated with the passage of Proposition 
            13 in 1978, followed by Proposition 62, which was approved by 
            voters in 1986.  Proposition 62 guaranteed that all local tax 
            increases be approved by voters.  After Proposition 62, local 
            governments resorted to the use of fees and assessments, which 
            did not require voter approval, to fill the void.  Ten years 
            later, in 1996, the passage of Proposition 218 added Articles 
            XIII C and XIII D, providing voters with control over taxes 
            regardless of whether they were called assessments, fees, or 
            charges.  Proposition 218 also included a provision requiring 
            that special taxes receive two-thirds approval of the 
            electorate.  In 2000, however, Proposition 39 provided a 
            narrow exception to the two-thirds vote requirement for 
            special taxes by authorizing the passage of local school 
            construction bond measures by approval of 55% of voters. 

           5)General Tax vs. Special Tax  .  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 








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            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 are placed into the GF 
            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].  A general 
            tax must be approved by a majority vote of the electorate, 
            whereas a special tax may be imposed only with the approval of 
            at least two-thirds vote of the local voters.  SB 1492 
            authorizes the City and County to place before the voters an 
            ordinance to levy a local vehicle assessment for general 
            revenue purposes, rather than a specified purpose.  As such, 
            the ordinance only needs to be approved by a majority of the 
            county voters and does not require the supermajority vote 
            otherwise required for special taxes.  The local assessment 
            would be administered by DMV under contract with the City and 
            County, and DMV's costs would be recovered from revenue 
            generated by the assessment.

           6)State VLF  .  According to DMV, most vehicles are assessed a 
            VLF.  The VLF was established by the Legislature in 1935 in 
            lieu of a property tax on vehicles.  The VLF is a state tax 
            levied on the purchase price of a vehicle, and subsequently 
            annually assessed against the vehicle's value adjusted by a 
            statutory depreciation schedule.  Proposition 1A, approved by 
            the voters in November 2004, requires that VLF revenue from 
            the existing 0.65% rate be allocated to support local health, 
            mental health, and social services costs under Realignment, or 
            otherwise allocated to local government.  In February 2009, 
            the rate of the VLF was temporarily increased from the current 
            rate of 0.65% to a rate of 1.15%, except for commercial 
            vehicles with a gross weight of 10,000 pounds or more.  
            Revenues from the portion of the increase from 0.65% to 1% 
            were retained by the GF and revenues from the additional 
            increase of 0.15% were transferred to a newly created Local 
            Safety and Protection Account, which is continuously 
            appropriated for specific local public safety programs.  The 
            VLF rate increase was effective for registrations beginning 
            May 19, 2009 (corresponding to the timing of a weekly VLF 
            billing cycle) and expired on June 30, 2011.  

           7)Local San Francisco VLF  .  In 1993, AB 925 (Burton), authorized 
            the City and County to levy a 2% VLF for purposes of public 








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            transit financing so long as transit fares are not increased.  
            The fee would have required a two-thirds vote of the 
            electorate.  It has never been enacted by the City and County. 
             At the time of its enactment, it was estimated that the 
            surcharge could have yielded over $300 million for the City 
            and County.  However, the potential fee has effectively been 
            voided due to a recent increase in transit fares. 

           8)Deductibility of the VLF for Federal and State Income Tax 
            Purposes  .  As a personal property tax, the VLF is deductible 
            for both federal and state income tax purposes.  Thus, for 
            those who itemize deductions, up to 40% of the additional VLF 
            would effectively be borne by the state and federal 
            governments in the form of reduced income tax payments.  The 
            same would be true of a local VLF, such as that proposed by 
            this bill.  The purpose of this provision is to ensure that 
            the State GF is made whole for any losses arising from 
            additional income tax deductions claimed by the residents 
            because of the additional vehicle assessment.  The GF would be 
            reimbursed in arrears for this loss.  As an alternative to 
            reimbursing the GF for the loss that would result from the 
            deductions taken by taxpayers for the payment of local vehicle 
            assessments, the Committee may wish to consider amending this 
            bill to simply disallow a deduction under the PIT Law for the 
            local vehicle assessments authorized by this bill.  By 
            disallowing a deduction for local vehicle assessments, the 
            administrative burden placed on both DMV and FTB will be 
            minimized.  
           
          9)A Long Legislative History.   SB 1492 is the fifth time a local 
            VLF bill has been introduced in the California Legislature in 
            the last few years.  AB 799 (Leno, 2005) and AB 1590 (Leno, 
            2007) were very similar to this bill in that they would have 
            applied only to the City and County.  AB 799 was vetoed by 
            Governor Schwarzenegger stating that VLF fees take money away 
            from the hands of hard working Californians.  AB 1590 was 
            returned by the Senate Revenue and Taxation Committee without 
            action.  SB 223 (Leno, 2011) is almost identical to SB 1492 
            and was vetoed by Governor Brown citing that the Legislature 
            should focus on fashioning a broader revenue solution to our 
            state's fiscal crisis rather than a piecemeal approach.  In 
            2003, Governor Schwarzenegger repealed a $4 billion increase 
            in the "car tax" imposed earlier in that year.  Unfortunately, 
            Governor Schwarzenegger's repeal of the increase in the car 
            tax plunged the state into an even deeper budget crisis.  Many 








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            California think tanks have stated that billions of dollars in 
            potential new revenue sources may be found if the rate of the 
            VLF is restored to the pre-2003 rate, which would generate $6 
            billion dollars annually.  The Committee may wish to consider 
            whether to advance SB 1492, given that there is no substantial 
            difference between this bill and previous legislation that 
            Governor Brown vetoed.  The Committee may also wish to discuss 
            the Governor's concerns about VLF piecemeal legislation.

           10)Double-Referral  .  This bill was double-referred with the 
            Assembly Committee on Local Government and passed out of that 
            committee by a vote of 6-3 on June 13, 2012.  

           11)Similar Legislation  .  

          SB 223 (Leno), introduced in the 2011-12 legislative session, is 
            identical this bill.  SB 223 was vetoed by Governor Brown.   
            According to the Governor's message:

               This bill permits the City and County of San Francisco to 
               enact a voter-approved local assessment on vehicles 
               registered to a San Francisco address. 

               Before we embark on a piecemeal approach for one city, we 
               should try to fashion a broader revenue solution to our 
               state's fiscal crisis.

            SB 10 (Leno), introduced in the 2009-10 legislative session, 
            is identical to this bill.  SB 10 died in the Assembly. 

            AB 1342 (Evans), introduced in the 2009-10 legislative 
            session, authorizes counties, under specified circumstances, 
            to adopt a local PIT, a local VLF, or both.  AB 1342 was never 
            heard in this Committee and was returned to the Assembly Desk. 
             

            AB 1590 (Leno), introduced in the 2007-08 Legislative Session, 
            was similar to this bill, but was limited to the City and 
            County of San Francisco.  AB 1590 was held in the Senate 
            Revenue and Taxation Committee. 

            AB 799 (Leno), introduced in the 2005-06 Legislative Session, 
            is very similar to this bill, except it applied only to the 
            City and County of San Francisco.  AB 799 was vetoed by the 
            Governor.  In his veto message, the Governor stated:








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               Within hours of taking office in 2003, I signed an 
               Executive Order to reverse the car tax increase.  That 
               action returned $4 billion to the people of California.  
               Putting that money back into the hands of hard working 
               Californians is one of the ways we have helped our 
               economy grow over the last three years.

               This measure would, in effect, reinstate the car tax for 
               the people of San Francisco.  In fact, if the vehicle 
               license fee increase proposed by this bill were enacted, 
               the people of San Francisco could pay more than twice the 
               amount to register their vehicles than anyone else in the 
               state.

               As noted in my veto messages of prior years, I am not 
               opposed to modest increases in fees if such increases are 
               approved by the impacted voters and not addressed in a 
               piecemeal fashion.  Although this bill requires voter 
               approval, it impacts only one county.

                    AB 1208 (Yee), introduced in the 2005-06 Legislative 
             Session, would have imposed an additional VLF on the 
             residents of the City and County of San Francisco for the 
             purpose of funding maintenance and improvements of roads.  
             The fee would have been a flat fee per registered vehicle.  
             AB 1208 was vetoed by Governor Schwarzenegger.  

           REGISTERED SUPPORT / OPPOSITION :

           Support 
           
          City and County of San Francisco
          San Francisco Chamber of Commerce
           
            Opposition 
           
          California Taxpayer's Association
          California New Dealers Car Association

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











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