HomeMy WebLinkAboutRES 146 Draft 02 2000-2002 COUl®T'TY Off' I-iA~I`I ~~T~ O~ I3r~~V~.I`I
I~SOLiJTI010T 1®10.
ra t
RESOLUTION TO AUTHORIZE THE DIRECTOR OF FINANCE TO COMPROMISE
PENALTIES AND INTEREST PORTION OF REAL PROPERTY TAXES ASSESSED
AGAINST HAWAIIAN HOME LANDS HOMESTEAD LESSEES IN EXCHANGE FOR
THE DEPARTMENT OF HAWAIIAN HOME LANDS MAKING PAYMENT OF REAL
PROPERTY TAXES OWED HY HAWAIIAN HOME LANDS HOMESTEAD LESSEES
WHEREAS, the Congress of the United States in the Hawaiian Homes Commission Act
of 1920 and the State of Hawaii by Section 4~ of the Admission Act and Article XII, Section 3 of
the State Constitution, which adopted the Hawaiian Homes Commission Act as a compact with
the United States, have recognized areas to be set aside as Hawaiian Home Lands for the benefit
of native Hawaiians; and
WI-IEREAS, the administration of these Hawaiian Home Lands was placed with the
Department of Hawaiian Home Lands (hereinafter referred to as "DHHL"), pursuant to Section
202, Hawaiian Homes Commission Act; and
WHEREAS, Section 207 of the Hawaiian Homes Commission Act, authorizes DHHL to
lease to native Hawaiians the right to use and occupy these lands as homestead; and
WHEREAS, Section 208(7) of the Hawaiian Homes Commission Act, places as a
condition of the lease that the lessee shall pay all taxes assessed upon the tract, and
improvements thereon, after the initial seven years of the commencement of the lease; and
WHEREAS, Section 19-89, Hawaii County Code, affirms its recognition of the
Hawaiian Homes Commission Act of 1920; and
WHEREAS, Section 19-89, Hawaii County Code, states that DHHL lands used for
homestead shall be exempt from real property tax except for the minimum tax after the
seven-year limitation of Section 208, Hawaiian Homes Commission Act; and
WHEREAS, Section 19-89, Hawaii County Code, states that improvements upon
homestead leases shall be taxed and that it will qualify and receive other personal exemptions
that are timely filed; and
WHEREAS, numerous lessees on Hawaiian Home Lands Homesteads in Hawaii County
are delinquent on payment of real property taxes, penalties, and interests; and
WHEREAS, in the Hawaii State Supreme Court case of In re Ainoa, 60 Haw. 487
(1979), in affirming County's right to levy real property tax on Hawaiian Home Lands, the Court
recognized that it is the value of the underlying fee interest that is being assessed, and not the
leasehold. The Court further held that the improvements upon the lease is also taxable; and
WHEREAS, while the right to levy real property tax on Hawaiian Home Lands has been
recognized by the Hawaii State Supreme Court, the enforcement of that levy is not as clear.
Section 4 of the Admission Act provides that "the encumbrances authorized to be placed on
Hawaiian Home Lands by officers other than those charged with the administration of said Act,
shall not be increased, except with the consent of the United States". The Hawaiian Homes
Commission Act did not authorize the State or local government to apply tax liens to Hawaiian
Home Lands. To the extent that a real property tax lien is an encumbrance on the property
created by non-administrators of DHHL, an act of Congress would be required to attach it to
Hawaiian Home Lands. fine disposition of Hawaiian Home Lands by County tax sale would
seem to be in contravention of this intent where Section 19-37 states that the tax lien is upon "the
property assessed"; and
WHEREAS, pursuant to Hawaiian Homes Commission Act, Section 210, DHHL can
cancel the lease for nonpayment of taxes. Then, pursuant to Section 216(d) of the Hawaiian
Homes Commission Act, it is DHHL, not the County, which has the primary tax
collection/enforcement authority under the Hawaiian Homes Commission Act and has a first lien
against the lessee's interest for taxes and other expenses paid by DHHL; and
WHEREAS, foreclosure attempts on the improvements would also pose practical
problems in that the leases can only be given to qualified Native Hawaiians, according to priority
determined by DHHL; and
WHEREAS, DHHL, pursuant to Section 208(7), Hawaiian Homes Commission Act, may
pay the real property taxes owed by the homestead lessees and DHHL imposes a lien on that
lease, pursuant to Hawaiian Homes Commission Act, Section 216; and
WHEREAS, in 1994 the County Council of the County of Hawaii Committee on
Finance adopted Communication No. 449 authorizing the Director of Finance to compromise the
penalties and interests portion of real property taxes owed by lessees of Hawaiian Home Lands
Homestead in exchange for DHHL paying the real property tax of these lessees and the
delinquent real property tax was paid; and
_ _ _
WHEREAS, DHHL and the County of Hawaii in 1999 did enter into negotiations for a
Memorandum of Agreement to compromise the penalties and interest portions of real property
taxes owed by Hawaiian Homestead lessees in exchange for DHHL paying the taxes owed by the
lessees, but the parties could not resolve mismatching records of amount owed; and
WHEREAS, the DHHL has recently proffered full payment of real property taxes owed
by all individual lessees of Hawaiian Home Lands Homestead whose delinquency is in excess of
$500 as of December 31, 2001 in exchange for the penalty and interest portions of those
delinquencies being compromised; and
WHEREAS, Section 19-3, Hawaii County Code, gives the Director of Finance the
authority to compromise any claim exceeding $500 with the approval of Council with the
provisions that there shall be placed on file and in the Department of Finance office a statement
of (A) the amount of tax assessed, or proposed to be assessed, (B) the amount of penalties and
interest imposed, or proposed to be assessed, (C) the amount of penalties and interest imposed or
which could have been imposed by law with respect to item (A), as computed by the director,
(D) the total amount of liability as determined by the terms of the compromise, and the actual
payments thereon with the dates thereof, and (E) the reasons for the compromise; and
WHEREAS, the Director of Finance, having complied with the provisions of Section
19-3, seeks authorization and approval of the Council to compromise the amount in penalties and
interest owed by individual lessees of Hawaiian Home Lands Homestead.
NOW, THEREFORE, BE IT RESOLVED BY THE COUNTY COUNCIL OF THE
COUNTY OF HAWAII, that in accordance with Section 208(7), Hawaiian Homes Commission
Act, Sections 19-3(12) and 19-89, Hawaii County Code, the Director of Finance is authorized to
compromise the penalties and interest owed by lessees of Hawaiian Home Lands Homestead
whose tax delinquencies exceed $500 by December 31, 2001.
BE IT FURTHER RESOLVED that the County Clerk shall forward copies of this
Resolution to (I) the State of Hawaii, Department of Hawaiian Home Lands; and (2) William
Takaba, Director of Finance, County of Hawaii.
DATED: Hilo, Hawaii,
INTRODUCED BY:
~ ~ ~ ~
COUNCIL MEMBER, COUNT AWAI`I
s:resolutions\dhhltaxcompromise\CTMmkk:10-01
COUNTY COUNCIL ROLL CALL VOTE
County of Hawal`i AYES NOES ABS EX
H110, HaWal`1 ARAKAKI
CHUNG
1 hereby certify that the foregoing RESOLUTION was by ELARIONOFF
the vote indicated to the right hereof adopted by the COUNCIL of the JACOBSON
County of Hawaii on
LEITHEAD-TODD
ATTEST: PISICCHIO
SAFARIK
TYLER
YAGONG
COUNTY CLERK CHAIRMAN & PRESIDING OFFICER Reference: C- 416 1 /P-FC
RESOLUTION NO. (Draft: 2 )