HomeMy WebLinkAboutCOM 0813.009 1998-2000
BILL 276
AN ORDINANCE AMENDING CHAPTER 19, OF THE HAWAII COUNTY CODE
1983 (1995 EDITION), RELATING TO REAL PROPERTY TAXES
BY
BLANE YOKOTA
CORPORATE COUNSEL
FOR
VERIZON HAWAII
AUGUST 8, 2000
Good morning Committee Chair Chung and Members of the Hawaii
County Finance Committee. I am Blane Yokota, Corporate Counsel testifying on
behalf of Verizon Hawaii ("Verizon) formerly known as GTE Hawaiian Tel. Thank
you for the opportunity to testify regarding Bill No. 276, "AN ORDINANCE
AMENDING CHAPTER 19, OF THE HAWAII COUNTY CODE 1983 (1995
EDITION), RELATING TO REAL PROPERTY TAXES." With all due respect to
this Committee and the Council, Verizon strongly opposes Bill 276 and urges the
Committee to hold this bill for the following reasons:
(1) Bill 276 is unconstitutional in that it attempts to exercise taxing
powers with respect to personal property and other non-real
property assets of public utilities;
(2) Efforts by the County to directly tax the real property of public
utilities will result in double taxation;
(3) The fact that this Committee is even considering Bill 276
demonstrates the inherent difficulty in directly assessing and
administering a real property tax on public utilities; and
(4) Even assuming, that the constitutional and administrative difficulties
can be overcome, any increase in taxation revenues resulting from
county taxation of public utilities will ultimately be passed on to the
customers of utilities in the form of higher utility bills.
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(5) Verizon will begin paying a portion of its PSC tax under protest on
August 10, 2000. At the same time or at the lastest within 30 days after
making its first payment under protest Verizon will file a complaint
regarding the PSC tax and the double taxation issue. It is Verizon's hope
and intention that these actions will be followed by renewed negotiations
between the County and the State to resolve the double taxation issue.
First and foremost, Bill 276 is unconstitutional in that it purports to tax the
personal property and other non-real property assets of public utilities.
Notwithstanding the County's ongoing dispute with the State regarding real
property taxation, there is no legal authority whatsoever which grants the County
the right to tax personal property or any other non-real property assets.
Furthermore, Verizon understands that Bill 276 is based on a mainland statutory
model. However, that model is inapplicable to the instant situation because of
Hawaii's unique constitutional split regarding taxing authority. Verizon has been
unable to find any other statutory scheme similar to Bill 276 in which the taxing
authority does not possess the authority to tax both real property and personal
property.
Second, as Verizon testified last December of 1999, when the Council
was considering Bill 143, any attempt by the County to directly assess real
property taxes without a corresponding and concurrent change in the Public
Service Company tax will result in double taxation.
Third, that the Council is even considering Bill 276 demonstrates the
inherent difficulties in directly assessing and administering a real property tax
based on a valuation of utility assets where, as in this case the counties do not
have concurrent authority to tax personal property and other non-real property
assets.
Fourth, it should always be remembered that any ordinance change which
results in an increase in the overall tax burden on public utilities will ultimately be
passed on to the customers of utilities, the Council's constituents. Accordingly, a
tax on public utility real property should not be viewed as a pain-free way to
increase county revenues.
When the Council passed Bill 143, Verizon, formerly GTE and the other
utilities pledged to work on passage of legislation to amend Chapter 239, H.R.S.,
to achieve a sharing of the PSC tax revenues between the State and the
counties. Verizon continues to support efforts to resume negotiations between
the County and the State and will once again champion a legislative solution to
the ongoing dispute regarding real property taxation. Such a solution is
preferable to Bill 276 in that it will finally address the constitutional split in taxing
authority between the State and the counties, it will be administratively workable
in that the current method of taxation and collection will be preserved, and it will
avoid any double taxation or increase in public utilities rates. For these reasons,
Verizon urges the Committee to hold Bill 276.
Lastly, Verizon respectfully submits that the action by the public utilities to
pay PSC taxes under protest will result in renewed settlement negotiations which
have the greatest chance of resolving the longstanding real property tax dispute
between the Counties and the State. Accordingly, passage of Bill 276 at this
time would not add any impetus to such negotiations nor contribute in a
meaningful way to the resolution of said dispute.
Thank you for the opportunity to provide testimony on this matter.