BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2114
                                                                  Page  1

          Date of Hearing:   May 14, 2014

                        ASSEMBLY COMMITTEE ON APPROPRIATIONS
                                  Mike Gatto, Chair

                     AB 2114 (Pan) - As Amended:  April 30, 2014

          Policy Committee:                              Revenue &  
          Taxation     Vote:                            7-0

          Urgency:     No                   State Mandated Local Program:  
          Yes    Reimbursable:              Yes

           SUMMARY  

          This bill imposes a tax on every qualified renter of qualified  
          heavy equipment (QHE) at the rate of 0.75% of the rental price  
          and provides that, for the 2015-16 Fiscal Year (FY) and for each  
          FY thereafter, this tax shall be in lieu of any personal  
          property tax on QHE.  In summary, this bill:

          1)Defines "qualified heavy equipment" as construction,  
            earthmoving, or industrial equipment that is mobile, including  
            industrial electrical generation equipment, lift equipment,  
            shoring, shielding, and ground trenching equipment, and  
            certain vehicles not designed to be driven on highways or  
            subject to Vehicle License Fees. 

          2)Defines a "qualified renter" as a renter whose principal  
            business is the short-term rental of QHE and is engaged in a  
            line of businesses described in Code 532412 of the North  
            American Industry Classification System.

          3)Requires the Board of Equalization (BOE) to administer and  
            collect the tax, requires every qualified renter to register  
            with the BOE, provides that the taxes shall be due and payable  
            quarterly, and amounts collected, less refunds and BOE  
            administrative costs, shall be deposited in the General Fund  
            (GF). 

          4)Directs county auditors to increase the total amount of real  
            property tax revenue to be allocated by the total amount of ad  
            valorem property tax revenue received by the county and each  
            city and special district in the county in FY 2013-14 from  
            renters of QHE (the "QHE reimbursement amount"), and decrease  








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            contributions to the county's Educational Revenue Augmentation  
            Fund (ERAF) by the same amount; provides additional  
            instruction to county auditors in the event that a county's  
            ERAF does not have sufficient funds to offset the QHE  
            reimbursement amount.

           FISCAL EFFECT  

          1)Significant costs, likely greater than $250,000, to the BOE to  
            establish and administer the QHE rental tax program.

          2)BOE estimates increased revenue of approximately $16.7 million  
            annually from the QHE rental tax.  However, The LAO estimated  
            in a 2013 analysis that foregone property tax revenues will  
            likely be between $20 million and $25 million.  Any negative  
            difference between GF revenues from the QHE rental tax and  
            foregone property revenues will result in a net cost to the GF  
            as the state is required to backfill shifted school funds  
            under Proposition 98 (see Comment 3).

          3)Likely additional state mandated reimbursement of local costs  
            for adjustments and QHE property tax estimates for county  
            auditors.

           COMMENTS  

          1)  Purpose.   According to the author, current personal property  
            tax owed on rental heavy equipment is based on a tax rate of  
            1.25% and applied to the heavy equipment's value on January 1  
            of each year.  This bill would replace this method of  
            calculation with a 0.75% tax on the rental receipts from  
            short-term rental of heavy equipment.  The tax would be  
            administered and collected by the BOE, and counties will  
            receive a greater share of the real property tax to backfill  
            the loss of personal property tax.

            According to the sponsor, heavy equipment rental companies are  
            subjected to local personal property taxation that can result  
            in unfair and administratively inconsistent application.   
            Rental companies with multiple locations in the state are  
            subjected to valuation audits in each jurisdiction in which  
            they operate.  Those rental companies state that different  
            county assessors use different methods for valuing mobile  
            construction equipment, resulting in different valuations, and  
            therefore different taxes owed, on the same pieces of  








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            equipment.  This measure is intended to address that  
            inconsistency.

          2)  Fees or Taxes In Lieu of Personal Property Taxation.   The  
            Legislature is constitutionally authorized to provide  
            different taxes on personal property, or taxes or fees in lieu  
            of personal property taxes.  For example, in 1936, the  
            Legislature created the Vehicle License Fee and removed  
            vehicles from local county assessments and personal property  
            taxation, instead subjecting them to a fee administered by the  
            Department of Motor Vehicles.  This bill provides a similar  
            tax in lieu for heavy rental equipment.

          3)  County Make-Whole Provision.   This bill would result in a  
            significant reduction in personal property tax revenue for  
            several counties.  The bill addresses this problem with a  
            "make-whole" clause that directs county auditors to: (i)  
            increase the total amount of property tax revenue to be  
            allocated by a "QHE reimbursement amount"; and (ii) decrease  
            contributions to the county's ERAF by the same amount.  In  
            doing so, the counties will theoretically be made whole, while  
            the state will be required to reimburse the ERAF reductions.   
            State contributions to ERAF will be recovered, at least in  
            part, from the new rental tax.

            Based on current estimates, however, it appears unlikely the  
            new GF revenues from the rental tax will offset the state's  
            increased ERAF responsibilities.  The BOE estimates the new  
            tax will generate approximately $16.7 million annually, while  
            the LAO previously estimated that foregone property tax  
            revenues were likely between $20 million and $25 million.  The  
            difference between these two amounts represents a net cost to  
            the state.

            In addition, the precise amount of property tax revenues  
            currently generated from heavy equipment appears to be  
            unknown.  This will likely present a significant challenge to  
            county auditors calculating the "QHE reimbursement amount."

           Analysis Prepared by  :    Joel Tashjian / APPR. / (916) 319-2081