Multi State Business Tax

November 18, 2011

Federal law protects a non California based business from California income and franchise taxation for sales made to California through a California ‘independent contractor” distribution channel

Filed under: California,franchise tax,income tax,nexus,Public Law 86-272 — admin @ 10:03 am

We have discussed the federal law that exempts a non California based business from California income and franchise tax of net income from the sale of tangible personal property to California customers under certain circumstances. The federal law is easy to comply with if the only connection with California is delivery of product into California from out of state; with no employees or property in the state. See http://www.multistatebztax.com/?p=576.

Several things to remember about the federal law.  Your non California based business is not protected by the federal law from California income or franchise taxation if your business was formed under the laws of California; such as a California corporation, limited liability company or limited partnership. Also, remember, this federal law only protects you from the California income and franchise tax; not the California sales and use tax. Finally, it only applies to the sale of tangible personal property; not services or intangible property such as franchises, patents and trademarks.

You can still obtain federal protection if you deploy sales reps in California; provided that they limit their activities to solicitation of sales; as long as approval of the sales occurs out of state and the goods are shipped from a location outside of California. See http://www.multistatebztax.com/?p=580 and http://www.multistatebztax.com/?p=584.

There is also federal protection if you sell your product through certain non employees such as commission agents, brokers or other “independent contractors”.  However, this sales force must sell for other businesses too and hold themselves out to the public as in the business of selling for more than your company.

Federal exemption of this “independent contractor” distribution channel is broader than a channel of your own sales reps.  These independent contractors can actually approve sales and maintain non home offices. However, they can’t have any of your inventory other than samples. That means they can’t hold any of your goods on consignment “or any other type of arrangement with the company, except for purposes of display and solicitation … “ Franchise Tax Board Publication 1050 ( http://www.ftb.ca.gov/forms/misc/1050.pdf).

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies; and assists them with California income, franchise; and sales and use tax issues.

 

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:       714 273-6291

November 16, 2011

Income from activities of sales reps of non California based business not protected from California taxation by federal law

Filed under: California,franchise tax,income tax,nexus,Public Law 86-272 — admin @ 7:48 am

This is a third in a series about the exemption from California taxation of income from a non California based income from sale of tangible personal property to California customers. See http://www.multistatebztax.com/?p=576 and http://www.multistatebztax.com/?p=580.  Today we talk about what California activities of your sales rep that will take you out of the protection of federal Public Law 86-272.

By way of background, the federal law only protects sale of tangible personal property by a non California based business where the order is accepted out of state and the goods are shipped into California from an out of state location. Furthermore, the only California presence permitted is solicitation activities of sales reps. In other words, no other California employees or property; other than certain samples, cars and other home office equipment used by the sales reps in the course of its solicitation of sales activities.

We talked in the last blog about Franchise Tax Board Publication 1050 (http://www.ftb.ca.gov/forms/misc/1050.pdf) which described in some detail the permissible California sales rep activities under the federal law. That publication also contains California sales rep activities that takes the non California based business out of the protection of the federal law.

Here is the list of “unprotected activities” taken right out of Publication 1050:

“A. Unprotected Activities:

The following in-state activities … (unless when taken together, these prohibited activities establish only a trivial connection with California) … are not considered as either solicitation of orders or ancillary thereto or otherwise protected under P.L. 86-272 and will cause otherwise protected sales to lose their protection under P.L. 86-272:

1. Making repairs or providing maintenance or service to the property sold or to be sold.

2. Collecting current or delinquent accounts, whether directly or by third parties, through assignment or otherwise.

3. Investigating credit worthiness.

4. Installation or supervision of installation at or after shipment or delivery.

5. Conducting training courses, seminars or lectures for personnel other than personnel involved only in solicitation.

6. Providing any kind of technical assistance or service including, but not limited to, engineering assistance or design service, when one of the purposes thereof is other than the facilitation of the solicitation of orders.

7. Investigating, handling, or otherwise assisting in resolving customer complaints, other than mediating direct customer complaints when the sole purpose of such mediation is to ingratiate the sales personnel with the customer.

8. Approving or accepting orders.

9. Repossessing property.

10. Securing deposits on sales.

11. Picking up or replacing damaged or returned property.

12. Hiring, training, or supervising personnel, other than personnel involved only in solicitation.

13. Using agency stock checks or any other instrument or process by which sales are made within this state by sales personnel.

14. Maintaining a sample or display room in excess of two weeks (14 days) at any one location within the state during the tax year.

15. Carrying samples for sale, exchange or distribution in any manner for consideration or other value.

16. Owning, leasing, using or maintaining any of the following facilities or property in-state:

a. Repair shop.

b. Parts department.

c. Any kind of office other than an in-home office as described as permitted under IV.A.18 and IV.B.2 … (of Franchise Tax Board Publication 1050).

d. Warehouse.

e. Meeting place for directors, officers, or employees.

f. Stock of goods other than samples for sales personnel or that are used entirely ancillary to solicitation.

g. Telephone answering service that is publicly attributed to the company or to employees or agents of the company in their representative status.

h. Mobile stores, vehicles with drivers who are sales personnel making sales from the vehicles.

i. Real property or fixtures to real property of any kind.

17. Consigning stock of goods or other tangible personal property to any person, including an independent contractor, for sale.

18. Maintaining, by any employee or other representative, an office or place of business of any kind …; other than an in-home office located within the residence of the employee or representative that (i) is not publicly attributed to the company or to the employee or representative of the company in an employee or representative capacity, and (ii) so long as the use of such office is limited to soliciting and receiving orders from customers; for transmitting such orders outside the state for acceptance or rejection by the company; or for such other activities that are protected under P.L. 86-272 or under paragraph IV.B. … (of Franchise Tax Board Publication 1050).

A telephone listing or other public listing within the state for the company or for an employee or representative of the company in such capacity or other indications through advertising or business literature that the company or its employee or representative can be contacted at a specific address within the state shall normally be determined as the company maintaining within this state an office or place of business attributable to the company or to its employee or representative in a representative capacity. However, the normal distribution and use of business cards and stationery identifying the employee’s or representative’s name, address, telephone, fax numbers and affiliation with the company shall not, by itself, be considered as advertising or otherwise publicly attributing an office to the company or its employee or representative.

The maintenance of any office or other place of business in this state that does not strictly qualify as an “in-home” office as described above shall, by itself, cause the loss of protection under  … (Public Law 86-272)

(I)t is not relevant whether the company pays directly, indirectly, or not at all for the cost of maintaining such in-home office.

19. Entering into franchising or licensing agreements; selling or otherwise disposing of franchises and licenses; or selling or otherwise transferring tangible personal property pursuant to such franchise or license by the franchisor or licensor to its franchisee or licensee within the state.

20. Conducting  activity not listed in paragraph IV.B. … (of Franchise Tax Board Publication 1050) … which was discussed in the previous blog) … which is not entirely ancillary to requests for orders, even if such activity helps to increase purchases.”

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies; and assists them with California income and franchise tax issues.

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:       714 273-6291

November 15, 2011

Sales Rep Distribution Channel by Out of State Based Business and Exemption from California Taxation of Income under Federal Law

Filed under: California,franchise tax,income tax,nexus,Public Law 86-272 — admin @ 11:02 am

Yesterday we talked in general about the exemption from California taxation of income from the sale of tangible personal property to California customers provided by federal Public Law 86-272.  See Federal law shields some out of state businesses from California taxation of income on sale of tangible personal property to California customers; http://www.multistatebztax.com/?p=576

Today we talk about how an out of state business can take advantage of the federal tax exemption on California taxation from sale of tangible personal property to California customers by your sales reps.  The general rule is that your reps can only solicit sales; the sales must be approved out of state and the goods must be shipped from out of state. Furthermore, your only in California presence can be the solicitation activities of your sales reps; no other employees or property.

California has published a helpful guideline listing what sales reps can do under the protection of the federal exemption and also what sales rep activities would take the non California based business out of the protection of the federal law.  See Franchise Tax Board Publication 1050 http://www.ftb.ca.gov/forms/misc/1050.pdf.

This blog will highlight some of the “protected activities” of a California sales rep distribution channel that are exempt under federal law:

  • Soliciting orders for sales by any type of advertising.
  • Generally maintaining a non public home office to carry out solicitation activity; but with no public identification with the company.
  • Carrying samples and promotional materials only for display or distribution without charge or other consideration.
  • Furnishing and setting up display racks and advising customers on the display of the company’s products without charge or other consideration.
  • Providing a company car.
  • Passing orders, inquiries and complaints on to the home office.
  • Solicitation of retailers for purchase from the out of state business’s wholesaler.
  • Coordinating shipment or delivery without payment.
  • Checking a customer’s inventory for purpose of re-order but not for quality control.
  • Maintaining a sample or display room in one place for no more than 14 days.
  • Recruiting, training or evaluating sales personnel, including occasionally using homes, hotels or similar places for meetings with sales personnel.
  • Mediating direct customer complaints when the purpose thereof is solely for ingratiating the sales personnel with the customer and facilitating requests for orders.
  • Owning, leasing, using or maintaining personal property for use in the employee or representative’s “in-home” office or automobile that is solely limited to the conducting of protected activities. Therefore, the use of personal property such as a cellular telephone, facsimile machine, duplicating equipment, personal computer, and computer software that is limited to the carrying on of protected solicitation and activity entirely ancillary to such solicitation.

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies; and assists them with California income and franchise tax issues.

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:       714 273-6291

November 14, 2011

Federal law shields some out of state businesses from California taxation of income on sale of tangible personal property to California customers.

Filed under: California,franchise tax,income tax,nexus,Public Law 86-272 — admin @ 1:13 pm

Many out of state businesses can sell their products into California without subjecting their income to the California income or franchise tax. That is because of the federal Interstate Income Tax Law; commonly referred to as Public Law 86-272 (15 U.S.C. 381; http://uscode.house.gov/download/pls/15C10B.txt).

The federal law applies to out of state businesses who sell tangible personal property into California with very minimal physical presence in the state. That means no California office or inventory (other than samples carried by sales reps who only solicit sales). You can’t have any employees in California, other than sales reps who only solicit sales. The reps can’t accept any orders (they must be approved out of state) and the goods must be shipped from an out of state location.

The federal law only protects products that are tangible personal property. So real estate is out as well as intangible property like franchises, patents, copyrights, trademarks and service marks. Also services are not protected.

Also, the federal law only protects the sale of tangible personal property; so a lease, rental or license of a product is not protected.

So, you can sleep well knowing your income will not be taxed by California if your only connection to the state is selling tangible personal property to California customers through online and mail order distribution channels; that is no California property or employees.  It gets a little more complicated to comply with the federal law if you have sales rep or independent contractors selling your product in California. We will talk about using sales rep and independent contractor distribution channels in upcoming blogs.

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies; and assists them with California income and franchise tax issues.

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:       714 273-6291

November 4, 2011

Illinois Department of Revenue Applies New Market Sourcing Rule to Services

Filed under: apportionment,Illinois,sales factor,services — admin @ 2:09 pm

Historically, a non Illinois based service provider would pay Illinois income tax on that service revenue only if its performance cost in Illinois for the service was greater than the performance cost for the service in any other state. This rule changed for taxable years that ended on or after December 31, 2008. Now, Illinois will tax the service if the service was received in Illinois. This new rule is what is commonly called a market sourcing rule.

Recently an out of state publicly traded global provider of online and campus educational services asked the Illinois Department of Revenue what tuition it receives from two of its “three learning platforms; … online, or a combination of both in classroom and online courses” would be subject to Illinois income taxation under the market sourcing rule.

The market sourcing statute was specific about sourcing services provided to a business if it was not clear where the services were received; to the fixed place of business of the customer; and if not known; to the office of the business that ordered the service; and if not known to the billing address of the customer.

The Department first noted that the online only educational platform was a service and subject to the market sourcing rule because it is “not canned computer software that can be downloaded and saved by students.” It noted that the taxpayer did not know the state where a student participated in an online only course, or ordered an online only course. Therefore Illinois would tax tuition for online only courses billed to an Illinois address.

For courses received both online and on a campus, the Department  taxed the tuition if the campus portion of the course was located in Illinois; reasoning that the student probably did the online courses in Illinois. See Illinois Department of Revenue Private Letter Ruling IT 11-0002-PLR (09/06/2011); http://www.revenue.state.il.us/LegalInformation/Letter/rulings/it/2011/IT-11-00.

Comment:  Market sourcing has been the common approach by most states for the sale of tangible personal property. The same rule seems to be the trend for services; which is an important departure since its effect will be magnified as states evolve to a single sales apportionment formula.

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies.

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:       714 273-6291

October 28, 2011

New North Carolina Law on Forced Combined Tax Returns

Filed under: combined reporting,North Carolina — admin @ 8:12 am

North Carolina revised its law this year concerning taxation of certain intercompany transactions; effective for tax years beginning in 2012. The new law was adopted in response to widespread criticism of the old forced combined tax return law and its implementation by the Department of Revenue. The new law is N.C. Gen. Stat. § 105-130.5A

The new law only permits the Department of Revenue to require a combined return upon satisfaction of two conditions. First, it must make a factual determination that a corporation’s intercompany transactions lack economic substance or are not at fair market value. Second, combined reporting can only be required if adding back, eliminating or otherwise adjusting the intercompany transactions won’t adequately reflect North Carolina net income.

The new law states that an intercompany transaction has  “economic substance” if it (i) has “one or more reasonable business purposes other than the creation of State income tax benefits and (ii) has … economic effects beyond the creation of State income tax benefits … (; which) … may be satisfied by demonstrating material business activity of the entities involved in the transaction.”

“Fair Market” intercompany transactions have the same meaning as the related party transaction rules under Section 482 of the Internal Revenue Code.

Comment. A separate return state is always going to have intercompany transaction tax disputes; much like those under the Internal Revenue Code. Companies will resist forced combination or other intercompany transaction adjustments. A simpler system would be to make combined reporting for unitary businesses mandatory; like California.

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies.

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:       714 273-6291

October 20, 2011

A non California business can ask the Franchise Tax Board if it is subject to California franchise-income taxation.

Filed under: California,franchise tax,income tax,nexus — admin @ 9:32 am

In 2011, California made it easier for a non California based businesses to know whether it was subject to California franchise or income taxation. Now, a non California based business will be subject to California franchise or income taxation if it meets any of the following three conditions: (1) the lesser of 25% of its sales coming from California or $500,000 of California sales; (2) the lesser of 25% of its real and tangible personal property located in California or $50,000 of California property; or, (3) the lesser of 25% of its payroll in California or $50,000 of California payroll.

However, a non California based business that has less than the above sales/property/payroll thresholds would still be subject to California taxation if it is “”actively engaging in any transaction for the purpose of financial or pecuniary gain or profit”. The Franchise Tax Board recently announced that a business can ask the Franchise Tax Board whether it is taxable under this general standard. FTB Notice 2011-06; http://ftb.ca.gov/law/notices/2011/2011_06.pdf

Comment. A business that is below the sales/property/payroll thresholds will have to consider whether it wants to raise its visibility with the California taxing agencies by requesting a ruling. It will have to disclose its identity. This FTB Notice provides some comfort by saying such a business may still apply for the FTB Voluntary Disclosure Program (if it otherwise qualifies) in order to avoid penalties and limiting past return year exposures to six years.

The FTB Notice makes it clear that you can’t ask for a ruling that you fall below the sales, property and payroll thresholds.

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies.

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:       714 273-6291

October 19, 2011

Taxpayer Successfully Resists Forced Combination under pre-2007 New York Law

Filed under: combined reporting,economic substance,New York,unitary — admin @ 11:12 am

Yesterday we discussed a case where a taxpayer was forced to file a combined New York return with a wholly owned subsidiary because the intercompany transactions had no potential for profit. We go back to that case today, and look at intercompany transactions between the taxpayer and another wholly owned subsidiary that did not result in forced combination. Matter of the Petition of Kellwood Company, Tax Appeals Tribunal, September 22, 2011; http://www.scribd.com/doc/67294810/In-re-Kellwood-Co-DTA-No-820915-NY-Tax-Appeals-Tribunal-Sept-22-2011

The taxpayer, Kellwood Company, formed Shared Services, Inc. (KSS) to provide centralized payroll, accounts payable and accounts receivable functions for Kellwood. Kellwood engaged E&Y to compute an arm’s length range for the cost markup that should be charged by KSS to Kellwood for the services, which was determined to be 8%. Thus KSS charged Kellwood cost plus 8% for these intercompany services.

The Tribunal set out the convoluted hoops that the taxpayer must go through to avoid combination:

“Any analysis begins with the assumption that the subject transactions merit tax respect. When neither party challenges this assumption, the inquiry turns solely on whether the taxpayer has proven that the transactions were at arm’s length … However, where a party does challenge the transactions by alleging that they were entered into only to gain preferential tax treatment, the trier of fact must inquire into the subjective purpose and objective substance of the transaction … (In that case the) … taxpayer must prove that it engaged in the transaction for valid, non-tax business purposes and that the transaction has … purpose, substance, or utility apart from [its] anticipated tax consequences … Upon proving that a transaction merits tax respect, the taxpayer bears the burden of proving that the transaction was at arm’s length, in order to rebut the presumption of distortion … Once the presumption of distortion has been rebutted, the burden then shifts to the Division to provide a rationale as to why, absent distortion, the taxpayer should nonetheless be required to file its report on a combined basis.”

The Tribunal concluded that combination was not required:

Turning to the case at bar, we conclude that petitioner met its burden of proving a subjective business purpose for the KSS transactions. The record contains documentation clearly establishing a valid business purpose for entering into credit and collection contracts with KSS. Specifically, … evidence … (showed) … the potential for substantial cost-savings by streamlining processes while eliminating redundancies and reducing errors among the business units that form Kellwood. …Given the evidence in the record, we find that petitioner has carried its burden of proving that parties engaged in the KSS transactions with a significant non-tax business purpose. Accordingly, we conclude that the KSS transactions merit respect for tax purposes.

“We now proceed to the next inquiry under the distortion test, which is whether petitioner has shown the transactions at issue to be at arm’s length … This Tribunal has held that reliance upon the application of IRC § 482 is proper …, even in the absence of a federal audit … We find that petitioner has met its burden of proving arm’s length pricing for the KSS transactions. The E&Y report shows that the cost plus eight percent is consistent median markup applied by companies providing services similar to KSS.  … As such, we conclude that petitioner has met its burden of rebutting the presumption of distortion with regard to the KSS transactions.

“In light of the foregoing, the burden shifts back to the Division to … identify with particularity the activities or transaction which it claims give rise to distortion and explain how distortion arises from those activities or transactions …The Division has provided neither evidence nor a meritorious argument as to why 92combined reporting would be appropriate for KSS absent distortion.  Accordingly, we hold that the Division may not require petitioner to file a combined report with KSS.”

Comment. New York changed its combined reporting law in 2007. Now, if substantial intercorporate transactions are present, this constitutes a irrefutable distortion. Taxpayers can no longer rebut the presumption of distortion arising from substantial intercorporate transactions. It does not matter if the transactions are at arm’s length. This certainly is a move to simplicity in comparison to the analysis employed by the Tribunal in this case.

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies.

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:       714 273-6291

October 18, 2011

New York Tax Appeals Tribunal Finds No Economic Substance in Intercompany Transactions with Wholly Owned Subsidiary and Requires Combined Reporting

Filed under: combined reporting,economic substance,New York — admin @ 10:39 am

The New York Tax Appeals Tribunal required an out of state parent corporation to file a combined return with one of its unitary wholly owned subsidiaries because the intercompany transactions lacked economic substance. Matter of the Petition of Kellwood Company, Tax Appeals Tribunal, September 22, 2011; http://www.scribd.com/doc/67294810/In-re-Kellwood-Co-DTA-No-820915-NY-Tax-Appeals-Tribunal-Sept-22-2011

The taxpayer, Kellwood Company, is a Delaware corporation and based in Missouri. Kellwood “is a supplier of moderately priced fashion apparel and recreational products …” Kellwood owned a subsidiary (referred to as “KFR”) which factored Kellwood’s receivables by purchasing them (according to Kellwood) “at an arm’s length discount value” as determined by its accountants, E&Y.

New York is a separate reporting state. Combined filing may be permitted or required if reporting separately distorts the income of a taxpayer. In order to file a combined return, three tests must be satisfied: (1) common ownership and control (80%); (2) unitary relationship among corporations; and (3) distortion. All three tests must be met.

If there are substantial intercorporate transactions among corporations, distortion is presumed. During the years at issue, Taxpayers can rebut this presumption by demonstrating that the substantial intercorporate transactions were conducted at arm’s length.

The first two tests for combined reporting were satisfied. There was a unitary relationship; and common ownership and control. Furthermore, distortion was presumed because of the substantial factoring intercompany transactions between Kellwood and KFR.

Kellwood offered volumes of evidence that the transactions were at arm’s length, but the Tribunal was not persuaded. Specifically the Tribunal held that the factoring transactions were not conducted at arm’s length because there was no potential for profit:

“We hold that petitioner failed to meet its burden of proving that the KFR transactions are entitled to respect for tax purposes. In so holding, we agree with the Administrative Law Judge in determining that petitioner failed to clearly and convincingly prove that the transfers of receivables to KFR had any potential profit or objectively affected petitioner’s net economic position … As such, we hold that a prudent investor would not have engaged in the transfers of receivables for any objective non-tax business rationale. We conclude that the KFR transactions do not merit tax respect because petitioner failed to produce clear and convincing evidence that the transfers had any economic substance apart from tax considerations.”

Comment. New York changed its combined reporting law in 2007. Now, if substantial intercorporate transactions are present, this constitutes a irrefutable distortion. Taxpayers can no longer rebut the presumption of distortion arising from substantial intercorporate transactions. It does not matter if the transactions are at arm’s length.

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies.

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:       714 273-6291

 

October 17, 2011

Federal Court Holds Local Illinois Tax Discriminated Against Railroad

Filed under: discrimination,federal jurisdiction,transportation — admin @ 8:56 am

Most legal challenges to state taxation of multistate business are based on the dormant commerce clause of the federal constitution. Those challenges must generally be tried in state court under the Tax Injunction Act (28 U.S.C. Section 1341; http://www.law.cornell.edu/uscode/text/28/1341)  with very limited chance of getting a review by the U. S. Supreme Court.

This federal 7th Circuit Court of Appeals case is an example of an exception. Kansas City Southern Railway, Co. et v Koeller; No. 10-2333 (decided July 27, 2011); http://scholar.google.com/scholar_case?q=Kansas+City+and+Norfolk+Southern.+v.+Koeller&hl=en&as_sdt=2,11&case=16617787782587513556&scilh=0.

Railroads are protected from state and local tax discrimination by federal law under the Railroad Revitalization and Regulatory Reform Act (the “4-R Act)); 49 U.S.C. Section 11501; http://www.law.cornell.edu/uscode/49/11501.html#b_1. Furthermore, the 4-R Act gives railroads the right to challenge violations of the 4-R Act in federal court.

In this case, a local flood district for years financed its budget by an assessment on the owners of land in the district on a cost per acre basis; treating each acre in same. 99.5% of the land in the district was agricultural land.  In 2008, the flood district faced dramatic fuel increases. The district changed its assessment scheme for 2009 for land owned by the railroads, pipelines and utilities; resulting in 2009 assessment increases of 8,300% and 4,800% for the railroads. The new approach was based upon the relative benefits conferred upon these lands. The agricultural and other acreage was assessed under the old fee per acres basis.

The federal appeals court had no problem finding discrimination. However, it did not order the flood district to assess the railroad land the same way that the agricultural land was assessed. Instead it sent the case down to the federal district with order to permit the flood district “free to go back to the drawing board and craft an assessment that is nondiscriminatory.”

Comment. The federal court made it quite clear that it did not want to interfere with a state or local government’s ability to raise revenues more than was necessary to prevent discrimination under the 4-R Act.

By John McCauley: Mr. McCauley is a lawyer based in southern California who provides legal counsel to companies.

Email:         jmccauley@mk-law.com

Profile:       http://www.martindale.com/John-B-McCauley/176725-lawyer.htm

Telephone:  714 273-6291

 

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