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Tax Review Commission

MINUTES OF THE

TAX REVIEW COMMISSION

November 25, 1997 - 9:00 a.m. -- Room 405 State Capitol



Members Present:    
    Mr. Gary Cornia, Chair
    Mr. James B. Lee, Vice-chair
    Mr. Mark Buchi
    Sen. Lyle W. Hillyard
    Sen. George Mantes
    Ms. Carol McCormick
    Judge Jon Memmott
    Ms. Bonnie Miller
    Ms. Dorothy Owen
    Mr. W. Val Oveson    
    Rep. John Valentine
    Mr. Ray Wood



    
Members Excused:

Mr. Robert M. Graham
Rep. Judy Ann Buffmire
    
Staff Present:
    Mr. Bill Asplund
     Executive Director
    Mr. Bryant R. Howe
     Research Analyst
    Ms. Rebecca L. Rockwell
     Associate General Counsel
    Ms. L. Kaye Clark
     Secretary


Note:    A list of others present and a copy of materials distributed in the meeting are on file in the Office of Legislative Research and General Counsel.
    

1.    Call to Order and Approval of Minutes -- Chair Cornia called the meeting to order at 9:00 a.m. He welcomed members of the Tax Review Commission (TRC) and members of the Revenue and Taxation Committee.

     MOTION: Mr. Wood moved to approve the minutes of the October 17, 1997 meeting. The motion passed unanimously. Sen. Mantes, Ms. Miller, and Rep. Valentine were absent for the vote.         
*     Property Tax Methodology and Intangibles
    
a. Staff report _ Legal and administrative comparisons with other states     Rebecca L. Rockwell presented the information in the packet "Surveys of State Assessment Practices and Taxation of Intangibles" which includes state surveys highlighting property tax assessment practices and the taxation of intangibles. Ms. Rockwell highlighted the surveys as follows:

    Survey of Railroad and Utility Taxation Practices Among the States: This survey, prepared in 1993 by the State Board of Equalization and Assessment for the State of New York, addresses for the 50 states topics including: (1) the taxation of real property, personal property, and intangible property, including the classification of property; (2) gross receipts taxation; (3) information on assessing jurisdictions, including staff size and whether railroad and utility property is assessed by the state or local government; and (4) valuation methodology, including

the use of the unitary method, reporting requirements, and apportionment methods and requirements.

    50-State Property Tax Comparison Study: The Minnesota Taxpayers Association prepared this study in 1996 for the 1995 payable year. Addressing the issue of relative property tax burdens across the United States, this survey compares the states' effective property tax rates in urban, suburban, and non-urban areas for: (1) residential property; (2) homesteads; (3) commercial property; (4) industrial property; (5) apartments; and (6) non-homestead cabins in rural locations. The survey contains data for higher and lower valued properties. Ms. Rockwell noted that according to this study, Utah ranks 37th in commercial and industrial property for largest urban areas, with the exception of higher value commercial property where Utah ranks 39th.

    Property Taxes: The Exemption for Intangibles: Providing 50-state data for 1997, this survey prepared by consultants to Tax Management Inc., addresses: (1) the taxation of real property; (2) the taxation of personal property; (3) intangibles exemptions; and (4) whether states impose a tax on intangibles.

    State Examples: The Office of Legislative Research and General Counsel contacted each of the states affiliated with the Western States Association of Tax Administrators, asking the state to provide: (1) information on its assessment practices; and (2) for each class of property, property values and property taxes paid. The packet includes the responses that have been received to date and some additional valuation and tax data provided by the Multistate Tax Commission.

    Ms. Rockwell stated that her research found little uniformity among the states. She noted that to properly evaluate the findings, it is also necessary to understand each state's administrative process Mr. Asplund added that while Utah may value property at a higher rate than other states, Utah does not tax property at a high rate.     
    Mr. Wood requested that staff research statutes from other states regarding their definitions of intangible property versus intangibles. Mr. Asplund said that Kansas has a local option intangibles tax. Mr. Buchi said that the WilTel decision provided a list of intangibles that are exempt from taxation.

    b. Consultants report
    Lawrence C. Walters, Ph.D.; J. Michael Pinegar, Ph.D.; and James S. Schallheim, Ph.D.
distributed copies of their presentation titled "A Review of Centrally Assessed Property Issues in Utah." (A copy of the presentation is included in the history at the Office of Legislative Research and General Counsel.) The consultants reported on the following charges from the TRC: (1) review the procedures and methods of the Property Tax Division (the "Division"); (2)

compare methods used by taxpayers; (3) compare Utah values to other states; (4) consider alternative methods of taxation; (5) consider possible Constitutional amendments; and (6) propose a definition of intangibles.

    Mr. Walters concluded the presentation with the following findings and recommendations of the consultants:
Findings: Property Tax Division
*     Methods and judgements employed by the Property Tax Division are within the limits established by finance theory and best appraisal practice.
*     The judgements rendered result in unit values which are higher than in most other states.
*     The resulting tax burdens placed on centrally assessed taxpayers are relatively high compared to other states, but are consistent with effective rates in several states.
*     The methods employed by the Property Tax Division do capture intangible property value, if it exists.
Findings: Intangibles
*     There is no generally agreed upon method for identifying and isolating intangible value from the enterprise unit value.
*     Adjustment methods which start from unit value generally have a substantial ad hoc component.
*     The only certain way to avoid taxing intangible property is to abandon the market value standard and use reproduction cost.
Recommendation: Market Value
*     Market value provides a basis for taxation which is consistent with      appraisal theory and the practice of most states.
*     Local assessment methods are tied closely to market value.
*     Market value provides a link to economic growth.
*     The State has market value expertise.
Findings: Gross Receipts Tax
*     A gross receipts tax would either treat taxpayers differently and therefore unfairly, or
*     It would result in important shifts in tax incidence for taxpayers and tax revenues for local governments.
*     A gross receipt tax would make the state tax system less stable and less resilient in the event of an economic downturn.
Recommendation
*     Tax all assets, except a specific list of exemptions.
*     If this option proves infeasible, tax only the reproduction cost of Utah tangible assets.

    c. Discussion
    Mr. Wood asked about the changes that would be necessary to tax all assets. Mr. Walters explained that because there is no practical process to distinguish between tangible and intangible property, the best solution is to amend the Utah Constitution to allow taxation of all

assets. Commissioner Oveson commented that changing the Constitution would have a significant impact on locally assessed commercial property, especially regarding enterprise values. Mr. Walters responded that the Legislature would have the flexibility to address those issues through the list of exemptions. Mr. Wood asked the consultants to explain the reasons for amending the Constitution in 1931 to not tax intangibles, and what has changed since then to require another amendment. Mr. Walters said the motivation to amend the Constitution in 1931 was the concern regarding double taxation and the ability to identify intangibles in the property tax. He stated that because the economy has changed, and theory and practice have advanced considerably since 1931, it is time to update the Constitution.

    The TRC then discussed Sen. Hillyard's suggestions that the language in the statutory definition of "property" be changed by replacing 'or other tangibles' with 'copyrights or patents' and that the 5 mil cap on intangible property be removed from the Constitution. Mr. Buchi stated that the impact of any changes on locally assessed properties needs to be considered. Judge Memmott said that because of the inequities in the gross receipts tax, that option should not be considered. He also recommended that the TRC first assist the Legislature by preparing a list of intangibles that should not be taxed and then review the appraisal methods.

    MOTION
: Judge Memmott moved that the TRC recommend that at this time the Legislature not consider a gross receipts tax. Sen. Hillyard spoke against the motion.

    Mr. Buchi declared a conflict of interest.

    The motion failed with Sen. Hillyard, Sen. Mantes, Ms. McCormick, Ms. Miller, and Commissioner Oveson voting in opposition and Chair Cornia, Mr. Buchi, Judge Memmott, and Ms. Owen voting in favor. Rep. Valentine was absent for the vote. Chair Lee abstained from voting.

    The TRC next discussed the following options: (1) amending the Constitution; (2) amending the definition of intangibles; and (3) statutorily outlawing the stock and debt and direct capitalization methods. TAPE 3 SIDE A @ ABOUT 20-55 MIN IF MORE INFO IS NEEDED

     MOTION: Mr. Buchi moved that the TRC recommend to the Legislature that they support a joint resolution directing the Tax Commission to give little or no weight to the stock and debt and direct capitalization methods.

    Chair Lee and Commissioner Oveson each declared a conflict of interest.

    The motion passed with Sen. Hillyard, Sen. Mantes, Ms. Miller, and Ms. Owen voting in opposition. Rep. Valentine was absent for the vote. Chair Lee abstained from voting.

    The TRC then discussed issues related to fair market value, reproduction versus replacement costs, double taxation, and a list of exempt intangible assets. Mr. Wood distributed pages 55- 56 from the article "Extracting the Value of Intangible Assets from the Unit Assessment Method" which contains a list of common categories of intangible assets. The committee reviewed the list and discussed several options as to which intangibles to include as exemptions. Rep. Valentine explained the results of his research for the bill he sponsored during the special session.     
    MOTION: Sen. Hillyard moved that the consultants come up with no more than three classifications of standard deductions in value for intangibles. Chair Cornia requested that some of the TRC members with expertise in that area be involved with the consultants.

     SUBSTITUTE MOTION: Mr. Buchi moved that an additional analysis of what goes in the classes be added to the study, including centrally assessed and locally assessed properties. Mr. Walters said that information was not in the scope of the current analysis.

    Sen. Hillyard divided the motion. The TRC voted on the original motion. The motion passed unanimously. Judge Memmott was absent for the vote and Chair Lee abstained from voting.

    The TRC next voted on the second motion. The motion passed with Sen. Hillyard, Sen. Mantes, and Rep. Valentine voting in opposition. Judge Memmott was absent for the vote and Chair Lee abstained from voting.

    MOTION: Chair Cornia moved that staff from the Office of Legislative Research and General Counsel develop a list of intangibles for the TRC. Sen. Hillyard amended the motion to list intangible property rather than intangible attributes of property and that staff catagorize the intangibles along a continuum. Mr. Buchi suggested that members review list in the Arthur Anderson study. The motion passed unanimously. Judge Memmott was absent for the vote and Chair Lee abstained from voting.

    
Chair Lee thanked Lawrence C. Walters, J. Michael Pinegar, and James S. Schallheim for their research and report to the TRC.     
*     Individual Income Tax Issues
    
Bill Asplund reported that the changes in federal income tax will result in a $15 million increase in revenue for Utah in 1998. Bryant Howe distributed the handout "Summary of Selected Major Provisions of the Taxpayer Relief Act of 1997 and Effect on Utah Income Tax System." He reviewed the provisions of the bill and the impact on state income tax revenue including: (1) the child credit; (2) HOPE education credit; (3) lifetime learning credit; (4) qualified state tuition programs; (5) deduction for student loan interest; (6) education IRA; (7)

individual retirement arrangements; (8) capital gains; (9) capital gains-sale of principal residence; (10) corporate alternative minimum tax for small business; (11) estate tax exclusion for family owned businesses; (12) welfare to work tax credit; and (13) self employed health deduction. Mr. Asplund noted that state withholding will no longer track well with the federal forms. Commissioner Oveson stated that the Tax Commission has decided to adjust the state withholding schedule for this year rather than create a W4 for Utah because the full impact of the changes are not known.

4.    Other Business


    a. Information item _ Tax bills filed for the 1998 General Session

5.    Adjournment--

     MOTION: Sen. Hillyard moved to adjourn the meeting at 5:00 p.m. The motion passed unanimously. Judge Memmott was absent for the vote. F:\USERS\REVTAX\WPFILES\TRC\1997\MINUTE11.WPD


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