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HomeMy WebLinkAboutRES 035 Draft 01 2004-2006 t~ 66 ~j ®~~1 Y Ly ~~J~ ~OUN~~ ®1 ~1-1 WW ~1`~ ~ .a J~~~ ¦ O~ i'i' ~~`1 . '~4 ~ e , ~~09 Ngdd SOLU'T'ION NO. ~ A RESOLUTION RELATING TO A BILL AMENDING CIIAPTER 239, ILR.S., FOR INCLUSION IN TIIE 2005 IIAWAI`I STATE ASSOCIATION OF COUNTIES LEGISLATIVE PACKAGE WHEREAS, HSAC Secretary Romy Cachola, Councilmember of the City & County of Honolulu, has requested that member counties of the Hawai` i State Association of Counties consider a proposed bill, set forth as Exhibit "A" and attached to this resolution, for inclusion in the 2005 Hawaii State Association of Counties (HSAC) legislative package, as follows: RELATING TO THE PUBLIC SERVICE COMPANY TAX -Amends Section 239-2, H.R.S., to expressly levy and assess the public service company tax derived from the operation of a private sewer company or private sewer facility; Act shall supercede the Tax Appeal Court decision, In the lbdatter of the Tax Appeal of the Director of Taxation, State of IIavvaii v. Laie Treatanent Works, Ine., Tax Appeal Court, Case No. 02-0067. NOW, THEREFORE, BE IT RESOLVED IiY TIIE COUNCIL OF TILE COUNTY OF IIAWAI`I that it approves the foregoing proposal for inclusion in the 2005 Hawaii State Association of Counties Legislative Package as set forth in the attached exhibit; and BE IT FURTHER RESOLVED that a copy of this Resolution be transmitted by the County Clerk to the President of the Hawai` i State Association of Counties. Dated at Hilo , Hawaii, this 21st day of January , 2005. INTRODUCED B COUNCIL MEMBER, CO Y OF HAWAII GS/rf COUNTY COUNCIL ROLL CALL VOTE County of Hawaii AYES NOES ABS EX Hilo, Hawaii ARAKAKI X HIGA X I hereby certify that the foregoing RESOLUTION was by HOFFMANN X the vote indicated to the right hereof adopted by the COUNCIL of the HOLSCHUH X County ofHawai`ion Jariuar~ 21, 2005 IKEDA X ISBELL X ATTEST: JACOBSON P 1 LAGO ~ SAFARIK ~ 9 0 0 0 ~~~3' ~y~~ ~ l~lr ~ Reference: C-55.4/Waived PWIRC COUNTY CLERK CHAIRMAN & PRESIDING OFFICER RESOLUTION NO. EXHIBIT A .B. NO. A BILL FOR AN ACT RELATING TO THE PUBLIC SERVICE COMPANY TAX. BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF HAWAII: 1 SECTION 1. The purpose of this Act is to expressly levy and assess the public 2 service company tax upon the gross income derived from the operation of a private 3 sewer company or private sewer facility. The Legislature intends that this Act 4 supersede the Tax Appeal Court's decision, In the Matter of the Tax Aaaeal of the 5 Director of Taxation. State of Hawaii v. Laie Treatment Works. Inc., Tax Appeal Court, 6 Case No. 02-0067. The Legislature further intends that a "private sewer company" or 7 "private sewer facility" be a company or facility that is deemed a "public utility" under 8 paragraph (1) of the definition of that term in section 269-1, Hawaii Revised Statutes. 9 SECTION 2. Section 239-2, Hawaii Revised Statutes, is amended by amending 10 the definition of "gross income" to read as follows: 11 ""Gross income" means the gross income from public service company business 12 as follows: 13 (1) Gross income from the production, conveyance, transmission, delivery, or 14 furnishing of light, power, heat, cold, water, gas, or oil; 15 (2) Gross income from the transportation of passengers or freight, or the 16 conveyance or transmission of telephone or telegraph messages other OCS/010605/03: 25/mg pscreso.05 Page 2 .B. NO. 1 than mobile telecommunications services, or the furnishing of facilities for 2 the transmission of intelligence by electricity, by land or water or air: 3 (A) Originating and terminating within the State; 4 (B) By means of vessels or aircraft having their home port in the State 5 and operating between ports or airports in the State, with respect to 6 the transportation so effected; or 7 (C) By means of plant or equipment located in the State, between 8 points in the State; or 9 (3) Gross income from the transportation of freight by motor carriers (other 10 than as stated in paragraph (2)), or the conveyance or transmission of 11 messages or intelligence through wires or cables located or partly located 12 in the State (other than as stated in paragraph (2) or 13 (4) Gross income from the operation of a private sewer company or private 14 sewer facility: or 15 [(4)] ~ With respect to a home service provider of mobile telecommunications 16 services, "gross income" includes charges billed for mobile 17 telecommunications services provided by a home service provider to a 18 customer with a place of primary use in this State when the mobile 19 telecommunications services originate and terminate within the same 20 state; provided that all such charges for mobile telecommunications 21 services that are billed by or for the home service provider are deemed to pscreso.05 Page 3 , ~ . ~ O . 1 be provided by the home service provider at the customer's place of 2 primary use, regardless of where the mobile telecommunications services 3 originate, terminate, or pass through. Gross income shall not include: 4 (A) Any charges for or receipts from mobile telecommunications 5 services provided to customers of the home service provider whose 6 place of primary use is outside the State; 7 (B) Any receipts of a home service provider acting as a serving carrier 8 providing mobile telecommunications services to another home 9 service provider's customer; and 10 (C) Any receipts specifically from interstate or foreign mobile 11 telecommunications services taxable under Section 237-13(6)(E), 12 as determined by the home service provider's books and records 13 kept in the ordinary course of business. 14 For the purposes of this paragraph, "customer", "home service provider', 15 "mobile telecommunications services", "place of primary use', and "serving 16 carrier" have the same meaning as in section 239-22. 17 The words "gross income" and "gross income from public service company 18 business" shall not be construed to include dividends (as defined by section 235-1) paid 19 by one member of an affiliated public service company group to another member of the 20 same group; or gross income from the sale or transfer of materials or supplies, interest 21 on loans, or the provision of engineering, construction, maintenance, or managerial pscreso.05 Page 4 . ~ . ~ O . 1 services by one member of an affiliated public service company group to another 2 member of the same group. "Affiliated public service company group" means an 3 affiliated group of domestic corporations within the meaning of chapter 235, all of the 4 members of which are public service companies. "Member of an affiliated public service 5 company group" means a corporation (including the parent corporation) which is 6 included within an affiliated public service company group. 7 Where the transportation of passengers or property is fumished through 8 arrangements between motor carciers, and the gross income is divided between the 9 motor carriers, any tax imposed by this chapter shall apply to each motor carrier with 10 respect to each motor [sarfier-s] carrier's respective portion of the proceeds. 11 Where tourism related services are furnished through arrangements made by a 12 travel agency or tour packager and the gross income is divided between the provider of 13 the services on the one hand and the travel agency or tour packager on the other hand, 14 any tax imposed by this chapter shall apply to each person with respect to each 15 person's respective portion of the proceeds. 16 Accounts found to be worthless and actually charged off for income tax 17 purposes, at corresponding periods, may be deducted from gross income as specified 18 under this chapter so far as they reflect taxable sales, but shall be added to gross 19 income when and ff subsequently collected. 20 As used in this paragraph "tourism related services" means motor carriers of 21 passengers regulated by the public utilities commission." pscreso.05 Page 5 . ~ . ~ ¦ O . 1 SECTION 3. This Act shall apply to gross income derived from operation as a 2 private sewer company or private sewer facility that is accrued from July 1, 2005. 3 SECTION 4. Statutory material to be repealed is bracketed and struck through. 4 New material is underscored. 5 SECTION 5. This Act shall take effect on July 1, 2005. 6 INTRODUCED BY: 7 8 pscreso.05 CITY COUNCIL n I CITY AND COUNTY OF HONOLULU ~O ~ ~ V O 9 HONOLULU, HAWAII NO. RESOLUTION APPROVING FOR INCLUSION IN THE 2005 HSAC LEGISLATIVE PACKAGE A PROPOSAL TO EXPRESSLY IMPOSE THE PUBLIC SERVICE COMPANY TAX ON THE GROSS INCOME OF EACH PRIVATE SEWER COMPANY AND PRIVATE SEWER FACILITY. WHEREAS, Chapter 239, Hawaii Revised Statutes (HRS), establishes two alternative formulas for the imposition of the State public service company tax upon a public utility; and WHEREAS, under one alternative, the public service company tax is imposed at the four percent rate on the gross income of a public utility, and the proceeds are realized by the State in lieu of the State general excise tax; and WHEREAS, the second alternative becomes operative if a county exempts the real property of a public utility from the real property tax; and WHEREAS, if the county enacts such an exemption by ordinance, the public service company tax is imposed at a minimum 5.885 percent rate on the gross income of each public utility operating within the boundaries of that county, and: (1) The portion of the proceeds representing a four percent rate is realized by the State as a substitute for the State general excise tax; and (2) The portion of the proceeds in excess of the four percent rate is transmitted to the county as a substitute for the county real property tax; and WHEREAS, every county of the State has chosen to (1) exempt public utilities operating within the boundaries of the county from the real property tax and (2) receive instead a share of the public service company tax proceeds pursuant to the second alternative; and WHEREAS, the State Department of Taxation had imposed the public service company tax on every private sewer company and facility because they are considered to be "public utilities" under Section 269-1, HRS, which is part of the State public utility regulation law, and Chapter 239, HRS; and 1 OCS/010605/03: 25/mg CITY COUNCIL (l • 1 CITY AND COUNTY OF HONOLULU Q 5- O Q y HONOLULU, HAWAII NO. RESOLUTION WHEREAS, the Tax Appeal Court, however, has recently rendered a decision finding that the gross income of a particular private sewer is taxable under the general excise tax instead of the public service company tax (See In the Matter of the Tax Appeal of Director of Taxation, State of Hawaii, Tax Appeal Court, Case No. 02-0067, judgment entered August 19, 2004); and WHEREAS, the Court's decision rests on an omission of express language in Chapter 239, HRS, that the public service company tax is to be imposed on the gross income derived from the operation of a private sewer company; and WHEREAS, the State Director of Taxation has not appealed the decision; and WHEREAS, one effect of the decision is to stop the counties from receiving a share of the public service company tax proceeds derived from a private sewer company or facility; and WHEREAS, to rectify the situation, the Council finds that the State law should be amended to expressly provide that the gross income derived from the operation of a private sewer company or private sewer facility is subject to the public service company tax; and WHEREAS, the amendment will enable a county to again receive a share of the public service company tax proceeds from every private sewer company and facility if the county continues to exempt them from the real property tax; and WHEREAS, the Council finds that, from an administrative standpoint, the receipt of a share of the public service company tax proceeds is preferable to the imposition of the real property tax on a private sewer company or facility; now, therefore, BE IT RESOLVED by the Council of the City and County of Honolulu that this body approves for inclusion in the 2005 HSAC Legislative Package a proposal, attached as Exhibit A, to expressly impose the public service company tax upon the gross income of each private sewer company or private sewer facility; and 2 CITY COUNCIL /n~ I CITY AND COUNTY OF HONOWLU Q ~ ~ y U y HONOLULU, HAWAII NO. RESOLUTION BE IT FINALLY RESOLVED that the Clerk is directed to transmit a certified copy of this Resolution to the President of the Hawaii State Association of Counties. INTRODUCED BY: DATE OF INTRODUCTION: Honolu u, awau ounce mem ers 3 LINDA LINGLE ° ~ KURT KAWAFUCHI GOVERNOR ~~aM~ ~ DIRECTOR OF TAXATION JAMES R. AIONA, JR. ~ - ~ MARIE C. LADERTA LT. GOVERNOR DEGUTV DIRECTOR ~ ` S„O STATE OF HAWAII DEPARTMENT OF TAXATION 0 0. eox ~5s HONOLUW,HAWAl1 aGa06 = _ PHONE NO: (808) Sal-7570 ~ FAX NO: (906)58'7-1560 ~ r Z m on n r-t January 5, 2005 rr7 Uo rc-'` w ct: m (p r' The Honorable Romy M. Cachola ~ s. n~ City & County of Honolulu ~ n x Councilmember, District VII v°~I = 530 S. King Street, Room 202 Honolulu, HI 96813 Dear Cotmcilmember Cachola: Deputy Director Marie Laderta and I were pleased to meet with you yesterday to discuss important tax issues that affect the counties. I am writing to follow up on those discussions, specifically with regazd to the recent Tax Appeal Court decision, In the Matter of the Tax Appeal of Director of Taxation, State of Hawaii v. Laie Treatment Works, Inc., in the Tax Appeal Court of the State of Hawaii, Case No. 02-0067. The taxpayer in this case is Laie Treatment Works, Inc, aprivately-owned company that operates a sewage treatment plant in Laie. At issue in the case was whether income received by the taxpayer for sewer and/or wastewater treatment services was subject to the public service company ("PSC") tax or, in the alternative, the general excise tax ("GET"). Because such sewage companies aze classified as "public utilities" under Hawaii Revised Statutes 239-2 and 269-1, the Department of Taxation ("Department") azgued that the income derived from the taxpayer's public utility business was subject to the PSC tax, which is generally imposed at the rate of 5.885%7 (as compazed to the 4% GET). Because the definition of "gross income" in HRS § 239-2 does not specifically identify gross income generated by a private sewer company, the Tax Appeal Court rendered a decision in favor of the taxpayer. The result is that the taxpayer was found to be subject to the GET instead of the PSC tax. Under Act 64, Session Laws of Hawaii 2001, the counties were allowed to receive a portion of the PSC tax revenues as part of the counties' assertion that they lose real property tax revenues when public utilities pay the PSC tax in lieu of real property taxes. Pursuant to Act 64, the PSC tax revenue is divided between the State and the counties, whereby the State receives revenues attributable to 4% (of the 5.885% tax rate) and the counties receive the remaining 1.885% (in excess of the 4% state portion). Therefore, the Laie case has a fiscal impact on the counties, rather than the State as of July 1, 2001. ' The PSC tax rate ranges from 5.885% to 8.2%, depending upon the profitability of the taxpayer. See HRS § 239-5. Z Act 64 codified a settlement between the State and the counties to divide the 5.885% PSC tax revenues collected by the 5.885% tax rate. Under the settlement, the State received 4% of the public service company gross receipts The Honorable Romy Cachola January 5, 2005 Page 2 Our deputies attorney general working on the case have previously contacted the corporation counsels of each county to inform them of the case developments. Because of the potential fiscal impact on the counties, you may wish to consider a legislative fix to amend the definition of "gross income" in HRS § 239-2 to preserve the counties' 1.885% portion of the PSC tax revenues for the sewage treatment industry.3 Our current data shows that the counties received approximately $45 million in PSC tax revenue in Fl' 2004. We do not have the data that shows how much of this $45 million is attributable to privately-owned sewage andlor wastewater treatment companies in Hawaii. In addition, we also note that if such companies report their income under the GET system (instead of the PSC tax), the real property tax exemption in HRS § 239-3 no longer applies, and the counties may impose the real property tax on such public utilities, which may help to offset the revenue loss resulting from the Laie case. If you have any questions regarding the case, please call me at 587-1513 or Marie Laderta at 587-1527. We have enclosed a copy of judgment and our motion for summary judgment for your information. ry truly u K T KAWAFiJCHI Director of Taxation Enclosures rcachola-Ieie.ltr reported by taxpayers and the counties received 1.885%. The PSC tax is imposed in lieu of the GET (collected by the State) and the real property tax (collected by the counties). Because the GET is imposed at the rate of 4%, it was thought that the State was entitled to the 4%portion of the PSC tax, while the counties share in the 1.885% portion to compensate them for the loss of real property tax revenues. ' Additionally, the counties may have exposure for the back years (for which the statute of Limitations has not expired) as they may have to refund such portion of the 1.885% since July 1, 2001, when the counties began receiving such portion from the sewage treatment industry. MARK J. BENNETT, #2672 Attorney General of Hawaii MARY H.Y. BAHNG, #6454 Deputy Attomey General ' ' ' Department of the Attorney General, State of Hawaii C;.~=. r. Hale Auhau Building 425 Queen Street Honolulu, Hawaii 96813 Telephone: (808) 586-1470 Attorneys for Appellant DIRECTOR OF TAXATION, STATE OF H~,WAII IN THE TAX APPEAL COURT OF THE STATE OF HAWAII 1N THE MATTER OF THE TAX APPEAL CASE NO.02-0067 of JUDGMENT DIRECTOR OF TAXATION, STATE OF HAWAII, Appellant, vs. LAIE TREATMENT WORKS, INC, Taxpayer-Appellee. TRIAL DATE: November 29, 2004 JUDGMENT Taxpayer-Appellee LAIE TREATMENT WORKS, INC. ("Taxpayer"), filed Taxpayer- Appellee's Motion for Summary Judgment on Mazch 31, 2004 ("Taxpayer's Motion'. Appellant DIRECTOR OF TAXATION, STATE OF HAWAII ("Director', filed Appellant Director of Taxation, State of Hawaii's Motion for Pariial Summary Judgment Finding That ] 03119_ LDOC - . - Taxpayer Was a "Public Utility" and Consequently a "Public Service Company" During the Relevant Period on June 23, 2004 ("Public Utility Motion', and Appellant Director of Taxation, State of Hawaii's Motion for Partia] Summary Judgment Finding That Taxpayer's Income Generated from its Public Utility Business is Gross Income Subject to Public Service Company Tax on June 23, 2004 ("Gross Income Motion'. The Taxpayer's Motion, the Public Utility Motion and the Gross Income Motion all came on for hearing before the Honorable Gary W.B. Chang on July 12, 2004 at 9:00 a.m. By separate orders filed on ,the Court granted the Taxpayer's Motion and denied the Public Utility Motion and the Gross Income Motion. Pursuant to Rule 58, Hawaii Rules of Civil Procedure, Judgment is hereby entered in favor of Taxpayer and against the Director. DATED: Honolulu, Hawaii, "~O 1 ~ 2U04 PpPFJ~( Co GARY W.B. CFiAh1G `N ~ ~ A l s~ JUDGE OF THE ABOVE COURT In the Matter of the Tax Appeal of Director of Taxation. State of Hawaii v. Laie Treatment Works, ]nc.; Case No. 02-0067; Tax Appeal Court, State of Hawaii; Judgment 103 ] 19 ].DOC 2 ,r ' r` ^ n:pcA~ i ~-(i' r r MARK J. BENNETT, #2672 _ Attorney General of Hawaii i"°.' E,!J~ I Fi': C~ 23 MARY H.Y. BAHNG, #6454 , , Deputy Attorney General Department of the Attomey General, State of Hawaii Hale Auhau Bui]ding 425 Queen Street Honolulu, Hawaii 96813 Telephone: (808) 586-1470 Attorneys for Appellant DIRECTOR OF TAXATION, STATE OF H~IWAII IN THE TAX APPEAL COURT OF THE STATE OF HAWAII IN THE MATTER OF THE TAX APPEAL CASE N0.02-0067 of ORDER GRANTING TAXPAYER- APPELLEE'S MOTION FOR SUMMARY DIRECTOR OF TAXATION, JUDGMENT FILED MARCH 31, 2004 STATE OF HAWAII, Appellant, vs. HEARING DATE : July 12, 2004 LAIE TREATMENT WORKS, INC., TIME : 9:00 a.m. JUDGE: Hon. Gary W.B. Chang Taxpayer-Appellee. TRIAL DATE: November 29, 2004 ORDER GRANTING TAXPAYER-APPELLEE'S MOTION FOR SUMMARY JUDGMENT FILED MARCH 31.2004 Taxpayer-Appellee's Motion for Summary Judgment, filed March 31, 2004 ("Motion', came on for hearing before the Honorable Gary W.B. Chang on July ] 2, 2004 at 9:00 a.m. Alan J. Ma, Esq. and Owen H. Matsunaga, Esq. appeared on behalf of Taxpayer-Appellee LAIE TREATMENT WORKS, INC. ("Taxpayer"). Deputy Attomey General Mary H.Y. Bahng 103140_1.DOC appeared on behalf of Appellant DIRECTOR OF TAXATION, STATE OF HAWAII ("Director"). The Court having reviewed the records and files herein, having heazd the azguments and representations of counsel for Taxpayer and the Director, and being apprised of the premises herein, and good cause appearing therefor, IT I5 HEREBY ORDERED, ADJUDGED AND DECREED that the Motion is hereby GRANTED. t L~,` DATED: Honolulu, Hawaii, }paP~t CMG GARY W.B. CNANr N ~ ~ ~ l P JUDGE OF THE ABOVE- D COURT In the Matter of the Tax Appea] of Director of Taxation, State of Hawaii v. Laie Treatment Works, Inc.; Case No. 02-0067; Tax Appeal Court, State of Hawaii; Order Granting Taxpayer- Appellee's Motion for Summary Judgment filed Mazch 31, 2004 103 ] 40 l .DOC 2 +:~X APPEAI CO+~?' i GERSON & HIENEMAN ?P44 AUG 19 P?; 2~ 20 ALAN J. MA 5580-0 ;„(;~~~~;,,„,.;~,,,c:;+~ BRUCE D. HIENEMAN 6044-0 OWEN H. MATSUNAGA 5087-0 American Savings Bank Tower, Suite 780 C~ERIi 1001 Bishop Street _ Honolulu, Hawaii 96813 ~ ~ ~ O ~ Telephone: (808) 524-4800 I! it Facsimile: (808) 537-1420 Ali ~ ~ 2 3 ~ ~~J I. Attorneys for Taxpayer-Appellee LAIE TREATMENT WORKS INC. ~ attorney Gunere~s onic~ > ~ Tex DWfsinn•Le al Sectbn r' IN THE TAX APPEAL COURT OF THE STATE OF HAWAII IN THE MATTER OF THE TAX APPEAL ) CASE NO. 02-0067 OF ) ORDER DENYING APPELLANT DIRECTOR OF TAXATION, STATE OF ) DIRECTOR OF TAXATION, STATE OF HAWAII, )HAWAII'SM0170NFORPARTIAL SUMMARY JUDGMINT FINDING THAT Appellant, ) TAXPAYER'S INCOME GENERATED FROM ITS PUBLIC UTILITY BUSINESS IS v. ) GROSS INCOME SUBJECT TO PUBLIC SERVICE COMPANY TAX, FILED JUNE LAIE TREATMENT WORKS, INC., ) 23, 2004 Taxpayer-Appellee. )HEARING: Date: July ] 2, 2004 Time: 9:00 a.m. Judge: Honorable Gary W.B. Chang TRIAL DATE: November 29, 2004 Ordo Denyug GI M9.wpd r ORDER DENYING APPELLANT DIRECTOR OF TAXATION, STATE OF.HAWAH'S MOTION FOR PARTIAL SUMMARY JUDGMENT FINDING THAT TAXPAYER'S INCOME GENERATED FROM ITS PUBLIC UTILITY BUSINESS IS GROSS INCOME SUBJECT TO PUBLIC SERVICE COMPANY TAX, FILED .TUNE 23,2004 Appellant Director of Taxation, State of Hawaii's Motion for Partial Summary Judgment Finding That Taxpayer's Income Generated from its Public Utility Business Is Gross Income Subject to Public Service Company Tax, filed June 23, 2004 ("Motion', came on for hearing before the Honorable Gary W.B. Chang on July ] 2, 2004. Alan J. Ma, Esq. and' Owen H. Matsunaga, Esq. appeaeed on behalf ofTaxpayer-Appellee LAZE TREATMENT WORKS, INC. ("Taxpayer"). Mary H.Y. Bahng, Esq. appeared on behalf of Appellant DIRECTOR OF TAXATION, STATE OF HAWAII ("Appellant"). The Court having reviewed the records and files herein, having heazd the arguments and representations of counsel for Taxpayer and Appellant, and being apprised of the premises herein, and good cause appeazing therefor, IT IS HEREBY ORDERED, ADJUDGED AND DECREED that the Motion is hereby denied. DATED: Honolulu, Hawaii, Ally j G ~~U4 p~ C O GARY W.B. CHANG v~~ ~ ~ L JUDGE OF THE ABOVE-EN OURT Order Dcnying GI M51 wpd 2 r APPROVED AS TO FORM: MARY H.Y B;AHNG Attorney for Appellant DIRECTOR OF TAXATION, STATE OF HAWAII In the Matter of the Tax Appeal of Director of Taxation State of Hawaii v Laie Treatment Works, Inc.; Case No. 02-0067; Tax Appeal Court, State of Hawaii; Order Denying Appellant Director of Taxation, State of Hawaii's Motion for Partial Summary Judgment Finding That Taxpayer's Income Generated from its Public Utility Business Is Gross Income Subject to Public Service Company Tax, filed June 23, 2004 Order OrnyinE Gl M4wpd 3 nF tiau, GERSON & HIENEMAN if!!~~ AUG 14 PPI 2~ 19 ALAN J. MA 5580-0 ;~P1L~E~ ~.k,?.;~AR~'tE BRUCE D. HIENEMAN 6044-0 OWEN H. MATSUNAGA 5087-0 American Savings Bank Tower, Suite 780 CLEFsY 1001 Bishop Street ri 1 C r ~ O r~ c, - Honolulu, Hawan 96813 i ~ r7 (r' iC, Telephone: (808) 524-4800 I Facsimile: (808) 537-1420 I~~ t~ 2 3 ~ ' i~ _._-J Attorneys for Taxpayer-Appellee LAIE r c^' ` TREATMENT WORKS, INC. ~P IN THE TAX APPEAL COURT OF THE STATE OF HAWAII IN THE MATTER OF THE TAX APPEAL ) CASE NO. 02-0067 OF ) ORDER DENYING APPELLANT DIRECTOR OF TAXATION, STATE OF )DIRECTOR OF TAXATION, STATE OF HAWAII, )HAWAII'S MOTION FOR PARTIAL SUMMARY JUDGMENT FINDING THAT Appellant, ) TAXPAYER WAS A "PUBLIC UTILITY" AND CONSEQUENTLY A "PUBLIC v. ) SERVICE COMPANY" DURING THE RELEVANT PERIOD FILED ON JUNE 23, LAIE TREATMENT WORKS, INC., ) 2004 Taxpayer-Appellee. )HEARING: Date: July 12, 2004 Time: 9:00 a.m. Judge: Honorab]e Gary W.B. Chang TRIAL DATE: November 29, 2004 Ober DenyinE PU MSI wpd ti ORDER DENYING APPELLANT DIRECTOR OF TAXATION, STATE OF HAWAII'S MOTION FOR PARTIAL SUMMARY JUDGMENT FINDING THAT TAXPAYER WAS A "PUBLIC UTILITY" AND CONSEQUENTLY A "PUBLIC SERVICE COMPANY" DURING THE RELEVANT PERIOD FILED ON JUNE 23, 2004 Appellant Director of Taxation, State of Hawaii's Motion for Partial Summary Judgment Finding That Taxpayer Was a "Public Utility" and Consequently a "Public Service Company" During the Relevant Period, filed on June 23, 2004- ("Motion', came on for hearing before the Honorable Gary W.B. Chang on July 12, 2004. Alan J. Ma, Esq. and Owen H. Matsunaga, Esq. appeared on behalf of Taxpayer-Appellee LAIE TREATMENT WORKS, INC. ("Taxpayer"). Mary H.Y. Bahng, Esq. appeared on behalf of Appellant DIRECTOR OF TAXATION, STATE OF HAWAII ("Appellant"). The Court having reviewed the records and files herein, having heard the azguments and representations of counsel for Taxpayer and Appellant, and being apprised of the premises herein, and good cause appearing therefor, IT IS HEREBY ORDERED, ADJUDGED'AND DECREED that the Motion is hereby denied. AUG 1 9 2004 DATED: Honolulu, Hawaii, rt PPp~< iCiO~a GARY W.B. CHAI`iG m ~ ~ A 6 r JUDGE OF THE ABOVE- '~T COURT Order Denying PU MSJ.wpd 2 APPROVED AS TO FORM: J Ss/~i. Q _ MARY H.Y AHNG Attorney for Appellant DIRECTOR OF TAXATION, STATE OF HAWAII In the Matter of the Tax Appeal of Director of Taxation. State of Hawaii v. Late Treatment Works. lnc.; Case No. 02-0067; Tax Appeal Court, State of Hawaii; Order Denying Appellant Director of Taxation, State of Hawaii's Motion for Partial Summary Judgment Finding That Taxpayer Was a "Public Utility" and Consequently a "Public Service Company" During the Relevant Period filed on June 23, 2004 Ordn Omyng PU MSI wpd 3 MARK J. BENNETT, #2672 n' x o Attorney General of Hawaii T~ _ ~ ~h x m r ~D DIARY H.Y. BA}iNG, #6454 i N ='~v Deputy Attorney Genera] ~ ~ ~ -''a Department of the Attorney ' xr- I ~ ~ General, State of Hawaii I = w _ Hale Auhau Building i rn ~ 425 Queen Street Honolulu, Hawaii 96813 Telephone: (808) 586-1470 Attorneys for DIRECTOR OF TAXATION, STATE OF HAWAII IN THE TAX APPEAL COURT OF THE STATE OF HAWAII 1N THE MATTER OF THE TAX APPEAL CASE NO. 02-0067 of APPELLANT DIRECTOR OF TAXATION, STATE OF HAWAII'S MOT]ON FOR DIRECTOR OF TAXATION, PARTIAL SUMMARY JUDGMENT STATE OF HAWAII, FINDJNG THAT TAXPAYER'S INCOME GENERATED FROM ITS PUBLIC Appellant, UTILITY BUSINESS IS GROSS INCOME SUBJECT TO PUBLIC SERV]CE vs. COMPANY TAX; MEMORANDUM 1N SUPPORT OF MOT]ON; NOTICE OF LA]E TREATMENT WORKS, INC., HEARING OF MOT]ON AND CERT]F]CATE OF SERVICE ?axpayer-Appellee. HEARING DATE :July 12, 2004 TIME :9:00 a.m. JUDGE: Hon. Gary W.B. Chang ='8 9518? 2.DOC APPELLANT 1~IRECTOR OF TAXATION, STATE OF HAWAII'S MOTION FOR PARTIAL SUMMARY JUDGMENT FINDING THAT TAXPAYER'S INCOME GENERATED FROM ]TS PUBLIC UTILITY BUSINESS ]S GROSS INCOME SUBJECT TO PUBLIC SERVICE COMPANY TAX Appellant Director of Taxation, State of Hawaii ("Director"),t pursuant to Rule 29 of the Rules of the Tax Appeal Court and Rules 7 and 56 of the Hawaii Rules of Civil Procedure, moves this Court for pariia] summary judgment finding as a matter of law that income from the core of Taxpayer-Appellee Laie Treatment, Int.'s private sewer company/facility business is "gross income" subject to public service company tax on public utilities under Hawaii Revised Statutes Annotated chap~er 239 (Michie 2003). This Motion is based upon the memorandum attached hereto in support of the Motion, the records and files herein, and any further evidence and argument as may be presented upon the hearing of this Motion and related motions. DATED: Honolulu, Hawaii, June 23, 2004. MARK J. BENNETT Attorney General By: MARY H. . BAHNG Deputy Attorney General Kun Kawafuchi is the new Directcr of Taxation and is subsimted for former Director of Taxation Marie Y. Okamura, pursuant to Rule 25(d) of the Hawaii Rules of Civil Procedure. 95182 2.DOC 2 IN THE TAX APPEAL COURT OF THE STATE OF HAWAII 1N THE MATTER OF THE TAX APPEAL CASE N0.02-0067 of MEMORANDUM IN SUPPORT OF MOTION DIRECTOR OF TAXATION, STATE OF HAWAII, Appellant, vs. LAZE TREATMENT WORKS, INC., Taxpayer-Appellee. 95182_2.DOC TABLE OF CONTENTS I. INTRODUCTION ] II. PROCEDURAL BACKGROUND 2 Ill. STANDARD OF REVIEW ..............................................................................................2 IV. GENERAL RULES OF STATUTORY CONSTRUCTION 3 V. TAXPAYER'S GROSS 1NCOA9E FROM 1TS PUBLIC UTILITY BUSINESS IS "GROSS INCOA9E" FOR PSC TAX PUR.POSES ........................................................4 A. The History and Structure of the PSC Tax Requires the Inclusion of Gross Income ~ Generated From Private Sewer Company Business Within the Term "Gross income" Under HRS § 239-2 5 B. Taxpayer's Reading of the Statute Must be Avoided Because it Requires the Department of Taxation to Favor Private Sewer Companies and Potentially Violate the Equal Protection C]ause 7 I. All Public Utilities, Including Private Sewer Companies, are Within the Same Class far Tax Purposes 8 2. There is a Rational Basis for the Public Utility Classification I D 3. Taxpayer's Reading of the Statute Does not Give Equal Protection to Public Utilities 10 4. Unconstitutional Reoding of a Statute Must be Avoided I C. incompatibility Within HRS § 239-2 May be Reconci]ed 12 D. ]n re Hawaiian Telephone Co. is not Inconsistent With the Director's Position.. ]4 E. The Rules of Construction on Which Taxpayer Relies do not Resolve the Incompatibility in the Present Case and Their Application is Limited ] 6 VI. CONCLUSION I7 95182 2.DOC jj TABLE OF AUTHORITIES Federal Cases A]]eehenv PitisburQ Coal Co. v. Countv Comm'n of Webster Countv W. V , 488 U.S. 336, 109 S.Ct. 633 (]989) 8 Com¢an v. City ofNewaveo,.55 F.3d 12l l (6t° Cir. ]995) l0 Edward J. Debartolo Coro. v. Florida Gulf Coast Blde. & Constr. 485 U.S. 568, 108 S.Ct. 1392 (1988) ..................................................................................11, 12 Hawaii Consolidated Railwav v. Borthwick, 105 F.2d 286 (9`~ Cir. 1939) 8 Matsuda v. Wada, 128 F. Supp. 2d 659 (D. Haw. 2000) 11, ]2 State Cases Dines v. Pac. Ins. Co., Ltd., 78 Hawaii 325, 893 P.2d ] 76 (1995) 3 Hawaii Consolidated Railwav v. Borthwick, 34 Haw. 269 (1937) 5, 8 In re Gardens at West Maui Vacation Club v. County ofMaui, 90 Hawaii 334, 978 P.2d 772 999) ] 0 In re Hawaiian Telephone Co., 61 Haw. 572, 608 P.2d 383 (]980) 6, 14, I5, 16 in re ]stand Airlines, Inc., 47 Naw. 87, 384 P.2d 536 (1963) 6 in re Pac. Marine & Suuplv Co.. Ltd., 55 Haw. 572, 524 P.2d 890 (1974) ]0 in re Swann, 7 Haw. App. 390, 776 P.2d 395 (I989) 8 International Savines and Loan Association. Limited v. Wii2, 82 Hawaii 197, 92] P.2d l17 (1996) 76 Jones v. Hawaiian Elec. Co.. Inc., 64 Haw. 289, 639 P.2d 1103 (1982) 12 Kapiolani Park Preservation Soc. v. Citv and Countv ofllonolulu, 69 Haw. 569, 75] P.2d 1022 (1988) 11 Keliipu]eole v. Wilson, 85 Nawai'i 217, 221, 941 P.2d 300, 304 (]997) 7 Pan American Airways Co. v. Godbold, 36 Haw, l70 (1942) 1 l Pancakes of Hawaii. inc. v. Pomare Properties Corp 85 Hawaii 286, 944 P.2d 83 (App. 1997).2 Richardson v. City and Countv ofNonolulu, 76 Hawaii 46, 868 P.2d 1 ]93 (1994) 12, l3 95182 2.DOC jjj Sato v. Tawata, 79 Nawai'i 14, 897 P.2d 94l (1995) 3, 7 State v. Ogata, 58 Haw. 514, 572 P.2d 1222 (1977) 3 State v. Yan, 44 Naw. 370, 355 P.2d 25 960) ] 3 Cases Sandy Springs Water Co. v. Department of Health and Environmental Control, 324 S.C. 177, 478 S.E.2d 60 (1996) ]b State Statutes HRS § 1-16 (Michie 2003) 6 HRS § 232-1~1{Michie 2003) 2 HRS § 239-2 (Michie 2003) passim HRS § 239-4 (Michie 2003) 6, 7 HRS § 239-5 (Michie 2003) 1 4 7 , , HRS § 239-9 (Michie 2003) 6, ] 0 HRS § 269-1 (Michie 2003) 1, 9 Other Authorities N. 2-478, 15' Sess., at 7l ] (Haw. 7 963) 8 H. 2-792, 151 Sess., at 799 (Haw. 1963) 9, 10 H. 7-640, 151 Sess., at 800 (Haw. 7974) 9 N. Singer 2A Sutherland Statutory Construction, § 47.17 (6t° ed. 2000) 12, l3 N. Singer 2A Sutherland Statutory Construction, § 47.18 (6`" ed.2000) 13 S. 16-6, 2"" Sess., at 34-35 (Haw. 1932) 5 ' S. 7-587, ]S1 Sess., at 978 (Naw. 1974) 9 S. 7-777, 151 Sess.; at 1048 (Haw. 1974) 9 95 t 82_2.DOC jp MEMORANDUM IN SUPPORT OF MOT10N la INTRODUCTION Hawaii Revised Statutes Annotated ("HRS") § 239-5 (Michie 2003) imposes a public service company ("PSC") tax upon "each" public utility on its "gross income" from its public utility business. Although a private sewer company or facility ("private sewer company") is a "public utility" under HRS 239-2 and 269-] (Michie 2003), the definition of "gross income" in HRS § 239-2 does not specifically identify gross income generated from a private sewer company. HRS § 239-2, however, is prefaced with the caveat "unless otherwise required by context." In the present case, the conext, the history and the structure of the PSC tax requires that the gross income from Taxpayer's core public utility business be included within the term "gross income." To construe the definition otherwise would mean that the PSC tax on public utilities does not apply to a member of the public utilities classification (private sewer companies) under any circumstances while it applies to all other public utilities. This is an absurd and unjust result that (1) is inconsistent with and illogical given the history and structure of PSC tax on public utilities and (2) requires the Department of Taxation to treat private sewer companies more favorably than other public utilities and potentially violate the Equal Protection Clause. ~ Accordingly, Appellant Director of'Taxation, State of Hawaii ("Director"), respectfully moves this Court for partial summary judement finding that, as a matter of law, gross income ~ The Hawaii State Constitution, Article 1, Section 5, in pertinent pan provides: No person shall be denied the equal protection of the laws. Section 1 ofthe Fourteenth Amendment of the United States Constitution in peninem pan provides: No State shall deny to any person within itsjurisdiction the equal protection of the laws. 95182_2.DOC generated from~the core of'faxpayer-Appellee Laie Treatment Works, Inc.'s ("Taxpayer'? .private sewer company business is "gross income" subject to PSC tax under HRS chapter 239. Il. PROCEDURAL BACKGROUND Taxpayer filed its motion for summary judgment on March 31, 2004 arguing in essence that: (l) the income generated from Taxpayer's public utility business is not "gross income" under HRS § 239-2 and (2) Taxpayer was not a "public utility" solely because it did not obtain a certificate of public convenience and necessity. The isstf,e of whether the income generated from Taxpayer's public utility business is "gross income" depends on whether Taxpayer is a "public utility." Accordingly, "Appellant Director of Taxation, State of Hawaii's Motion for Partial Summary Judgment Finding that Taxpayer is a `Public Utility' and Consequently a 'Public Service Company"'("Director's Public Utility MPSJ") is concurrently filed with this Motion. Rather than repeat the content thereof, the Director incorporates by reference herein the Director's Public Utility MPSJ (including related papers) in its entirety. The Director files this Motion without awaiting the resolution of the Director's Public Utility MPSJ because Taxpayer has raised this "gross income" issue in Taxpayer's MSJ, for which the hearing has already been scheduled. 111. STANDARD OF RE\'lE\\' 'The hearing before the tax appeal court shall be a hearing de novo. HRS § 232-13 (1`9ichie 2003). Further, irrespective of which party prevails in proceedings before a state board of review. the assessment as made by the assessor shat] be "deemed prima facie correct." Id. Summary judgment is proper where the moving parry demonstrates that there are no eenuine issues of material fact and it is entitled to judgment as a matter of law. Pancakes of Hawaii ]nc. v Pomare Pronenies Corp 85 Hawaii 286, 291, 944 P.2d 83, 86 (App, 1997). 95182 2.DOC 2 Assuming that Taxpayer is a "public utility" and consequently a PSC, the issue raised in this N Motion is strictly a matter of Jaw and there are no genuine issues of material fact. Thus, partial summary judgment finding that, as a matter of law, Taxpayer's gross income from its core private sewer company business,is "gross income" subject to PSC tax is appropriate. IV. GENERAL RULES OF STATUTORY CONSTRUCTION Where the language of a statute is ambiguous or of doubtful meaning, or where literal construction of the statute would produce an absurd or unjust result, clearly inconsistent with the purposes and policies the statute was designed to promote, judicial construction and interpretation are warranted and also the court may resort to extrinsic aids to construction. State v. Oeata, 58 Haw. 514, 5] 8, 572 P.2d ]222 (1977). Rejection of even unambiguous language may be justified if there is "urunistakable support in the history and structure of the legislation." See Dines v Pac. Ins. Co., Ltd., 78 Hawaii 325, 332, 893 P.2d 776, 183 995). ]ndeed, the Hawaii Supreme Court has found: Our urimarv duty in interoretine and applyine statutes is to ascertain and eive effect to the leeislature's intention to the fullest decree. Although the intention of the legislature is to be obtained primarily from the language of the statute itself, we have reiected an a4proach to statutory construction which limits us to the words of a statute) 1 for when aid to construction of the meanine of words as used in the statute is available. there certainly can be no rule of law which forbids its use however clear the words may appear on superficial examination. Thus the plain laneuaee rule of statutory construction. does not preclude an examination of sources other than the laneuaee of the statute itself even when the lanauaee aupears clear upon nerfunctorv review. Were this not the case, a court maybe unable fo adequately discern the underlying policy which the legislature seeks to promulgate and, thus, would be unable to determine if a literal construction would produce an absurd or unjust result; inconsistem with the policies of the statute. [Citations, brackets, internal quotations marks, and ellipses points omined] [Emphases added.] Sato v. Tawata, 79 Hawaii 14, 17, 897 P.2d 941, 944 995). 951 s2 2.DOC 3 V. TAXPAYER'S GROSS 1NC0)\9E FRO)\9 1TS PUBLIC UTILITY BUSINESS IS "GROSS INCO)\9E" FOR PSC TAX PURPOSES HRS § 239-5 in pertinent part provides: § 239-5. Public utilities, generally. (a) There shall be levied and assessed upon each }iublic utility, a tax of such rate per cent of its gross income each year from its public utility business as shall be determined in the manner hereinafter provided " [Emphasis added.] HRS § 239-2 in pertinent part provides: § 139-1. DeTinitions. ~h,s used in this chapter unless otherwise required by context:.. . I1 "Gross income" means the gross income from public service company business as follows: (1) Gross income from the production, conveyance, transmission, delivery, or famishing of light, power, heat, cold, water, gas, or oil; (2) Gross income from the transportation of passengers or freight, or the conveyance or transmission of telephone or telegraph messages other than mobile telecommunications services, or the furnishing of facilities for the transmission of intelligence by electricity, by land or water or air or (3) Gross income from the transportation of freight by motor carriers (other than as stated in paragraph (2)), or the conveyance or transmission of messages or intelligence through wires or cables located or partly located in the State (other than as stated in paragraph (2) or (4)); or (4) With respect to a home service provider of mobile telecommunications services, "gross income" includes charges billed for mobile telecommunications services provided by a home service provider to a customer with a place of primary use in this State when the mobile telecommunications services originate and terminate within the same state:... (Emphasis added.] Taxpayer argues that none of its Bross income from its public utility business is subject to PSC tax because gross income of private sewer companies is not specifically identified within this definition. Taxpayer, however, ignores the fact that the definition of"gross income" is prefaced with the caveat "unless aherwise required by context" and the language "'Gross income' means the gross incomefi~onr public Bernice company business (emphasis added). 95182 2.DOC 4 Under Taxpayer's reading of the statute, the PSC tax on public utilities could not apply to a private sewer company, a public utility, under any circumstances. This is an absurd and unjust result that (1) is inconsistent with and illogical given the history and structure of PSC tax on public utilities and (2) requires the Department of Taxation to favor private sewer companies over the other public utilities and potentially violate the Equal Protection Clause. In the present case, context requires the inclusion of the gross income generated from Taxpayer's private sewer company business. A. The Nistory and Structure of the PSC Tax Requires the Inclusion of Gross Income Generated From Private Sewer Company Business Within the Term "Gross Income" Under HRS § 239-2 PSC tax on public utilities was established in 1932 when the tax system in Hawaii was being restructured. S. ] 6-6, 2"d Sess., at 34-35 (Haw. 1932). The Hawaii Supreme Court explained: The earning capacity of properly devoted to the utility business as reflected by gross income from utiiiN business and the ability to pay as reflected by net income from the same source, in other words; "yroTrs"from utility business, are the sole considerations in determining the amount of the tax.... Hawaii Consolidated Railway v. Bonhwick, 34 Haw. 269, 279-82 (1937). Act ]47, Hawaii Session Laws (]963); amended the definition of "gross income" to include the examples of types of gross income. Act 147 also added a new section requiring the allocation and separate accountings but only with respect to certain types of gross income identified in the new definition of Bross income. The examples of types of gross income appear to have been necessary to address the allocation requirement. `Act 14 i required the allocation of the following types of gross income: 95182_2.DOC 5 The intefrt to impose PSC tax on "each" public utility is still reflected within HRS chapter 239. As discussed in Director's Public Utility MPSJ, under NRS § 239-2, a "public utility" by definition is a "public service company," which is referred as "PSC" herein. HRS § 239-4 (Michie 2003) provides in relevant pari: § 239-4. Returns. Each public service companv shall file with the ofTce of the department of taxation a return in such for as the department may prescribe, showing its taxable gross income for the preceding taxable year.... (Emphasis added.] This language in HRS § 239-4 illustrates that the legislature intended for "each" PSC to have "gross income."~1' HRS § 239-9 (Michie 2003) in provides in relevant part: § 239-9. Time of application of tax and other provisions. (a) In genera]. The tax in~osed by this chapter applies ro every publfc service cornpany [Emphasis added.] The language could not be clearer: the PSC tax was intended to apply to "every" PSC. Laws in pari materio, or upon the same subject matter, shall be construed with reference to each other. HRS § I-] 6 (Michie 2003). 1f certain public utilities were not meant to be subject to PSC tax, the word "every" and "each" would be surplus language. ]t is a cardinal rule of statutory constmction that significance and effect shall, if possible, be accorded to every word. ]n re Hawaiian Telephone Co., 6] Haw. 572, 580 n.5, 608 P.2d 383, 388 n. 5 (1980) citing ]n re ]sland Airlines. ]nc., 47 Haw. 87, ] ] 2, 384 P.2d 536, 565 (1963). Courts are bound to give effect to all pans of a statute. and that no clause, sentence; or word shall be construed as supernuous, void; or insignificant if a construction can be legitimately found which will give force to an (2) Gross income from the transponation of pa<_sengers or freight. or the conveyance or transmission of telephone or telegraph messages, or the furnishing of facilities for the transmission of intelligence by electricity, by lands or air (3) Gross income from the ttansponation of freight by mover carriers (other than as stated in paragraph (2) of this subsection). or the conveyance or transmission of messages or intelligence through wires or cables located or partly located in the State (other than as stated in paragraph (2) of this subsection). 95782 2.DOC 6 preserve all words of the statute. Keliinuleole v. Wilson, 85 Hawaii 217, 221, 94] P.2d 300, 304 (1997). In accord, HRS § 239-4 provides in part: ]n case any public service company engages in lines of business other than its public service company business, the receipts therefrom shall not be subject to tax under this chapter, but the same tax liabilities shall attach to the public service company on account of the other lines of business as would exist if no public service company business were engaged in.... ]f the examples of "gross income" in HRS § 239-2 were intended to be exhaustive; this language in HRS § 239-4 would not be necessary. Indeed, Taxpayer itself asserts: "HRS § 239-5 subjects all public utilities to the PSC tax." See "Taxpayer's Mem. in Support of its MSJ, p. 10. It would be inconsistent and illogical with the history and structure of PSC tax to subject all public utilities to PSC tax without any possibility of actually subjecting the public utility to the tax. The court's "primary duty in interpreting and applying statutes is to ascertain and give effect to the legislature's intention to the fullest degree" Sato v. Tawata, 79 Hawaii l4, ] 7, 897 P.2d 94 944 (1995). In the present case, the legislature's intention was to subject all public utilities to PSC tax and that intention must be given effect to the fullest degree by including the gross income of'Taxpayer's core public service company business within the definition of "gross income" under HRS § 239-2. Taxpayer's Reading of the Statute Must be Avoided Because it Requires the Department of Taxation to Favor Private Sewer Companies and Potentially \~iolate the Equal Protection Clause The Taxpayer's reading of the definition of "gross income" requires the Department of Taxation to favor private sewer companies over all other public utilities and potentially violate the Equal Protection Clause and. therefore, must be avoided. 95182 2.DOC 7 ] . All Public Utilities. Includine Private Sewer Companies are Within the Same Class for Tax Purposes The Equal Protection Clause "applies only to taxation which in fact bears unequally on persons or property of the same class." ]n re Swann, 7 Haw. App. 390, 401, 776 P.2d 395, 399 (1989) citing Alleehenv Pittsburg Coal Co v County Comm'n of Webster County W V , 488 U.S. 336, 343, 109 S.Ct. 633, 637-38 (1989). When the legislature created the PSC tax back in ] 932, it put all public utilities into one classification: I•, ~W]e believe, the tax imposed by this Act is a substitute for ad valorem taxes.... By the Act utilities are put in a special class by themselves.... As ro the class affected the Act should Qperate uniformly and asideLom anv ineaualiN that Federal or local law might condemn it is reasonable to assume that the legislature intended complete eaualiN as to all utilities subiect to the Act. [Emphasis added.) Hawaii Con=olidated Railway v. Bonhwick, 34 Haw. 269, 281-82 (]937). The Ninth Circuit Court of Appeals affirmed this decision of the Hawaii Supreme Court and stated that "[iJt was reasonable to assume that the legislature intended to treat alike al] utilities subject to the act." Hawaii Con=o]idated Railwav v Bonhwick, ] OS F.2d 286, 287 (9'h Cir. 1939). ]n 1963; the PSC tax chapter v,~as amended by House Bill No. 57, which ultimately was enacted as Act ]47; Hawaii Session Laws (]963). Nouse Standing Committee ReportNo. 478, provides in pan that: The purpose of this bit] is to bring under one chapter the taxation of all businesses which are regulated by the public utilities commission.... H. 2-478, ]s' Sess.. at 711 (Haw. ] 963). House Standing Committee Report No. 792, in accord. provides in pan: Another purpose of this bill is to group businesses possessing those certain common characteristics of public utilities under one taxing 95]82 2.DOC $ chapter. It is felt that this type of grouping makes for better administration of the tax laws. H. 2-792, I S' Sess., at 799 (Naw. 1963). Private sewer companies were added to the definition of a "public utility" in HRS § 269- 1 in ] 974. Legislative committee reports stated the purpose of including private sewer companies and facilities in the definition as follows: The purpose of the bill is to include private sewerage disposal companies under the Public Utilities Commission thereby regulatine ilte rates that these companies charge for seweraee services. The bill accomplishes the purpose by amending section 269(-]], H. R. S., to include a person who operates a sewer company within the definition of a utility This will permit the commission to reeulate the rates chareed by such person and afford the consumer an opportunity to be heard with regard to such charges.... [Emphases added.) H. 7-640, ] s' Sess-, at 800 (Haw. ] 974). The purpose of this Bill is to reeulate the rates-and charees for seweraee services provided by private companies by_placing them under the control of the Public Utilities Commission. At the present time, the consumer affected has no alternative; but to accept the decisions of the private companies that own and operate sewer disposal plants. Presently, there is no regulation as to the amount a private company may charge for services. The proprietor of such companies need not justify or gain approval of any increases in rates. This Bill paces private seweraee disposal companies under the Public Utilities Commission thereby regulatine the rates that these companies charge. Under this new system. the consumers will be given reasons for any rate increases.... [Emphases added.] S. 7-587. Sess., at 978 (Haw. 1974): S. 7-777, ] r Sess.. at ] 048 (Haw. 1974). By including private sewer companies within the definition of "public utility," the legislature classified private sewer companies as a "public utility." 95 ] 82_ 2.DOC 9 2 There is a Rational Basis for the Public Utility ClassiTcation In analyzing tax classifications under the Equal Protection Clause, the Hawaii Supreme Court has stated that where discrimination is of a "non-suspect" or "non-invidious" variety, such discrimination is not unconstitutional if there is any rational basis for such classification. In re Gardens at West Maui Vacation Club v. Couniv of Maui, 90 Hawaii 334, 342, 978 P.2d 772, 780 (1999) citing In re Pac. Marine & Sunoly Co td , 55 Haw. 572, 581', 524 P.2d 890, 896 (1974). In the p~esent case, the legislature expressed that it believed that grouping all public utilities together in HRS chapter 239 "makes for better administration of the tax laws." H. 2- 792, 1~' Sess., at 799 (Haw. 1963). Bever tax administration is a rational basis for Equal Protection Clause analysis. See Sandy Sprines Water Co. v. Department of Health and Environmental Control, 324 S.C. 177, 182, 478 S.E.2d 60, 62 996)("administrative concerns may provide a rational basis for a legislative classification"); Comean v. Citv ofNewavao, 55 F.3d l21 (6t° Cir. 1995)("laws are rationally related to the administration of the tax system. Hence, the ordinance is not an arbitrary restriction, and the plaintiffs' Equal Protection rights have not been violated"). Thus, in the present case, there is a rational basis for the public utility classification. 3 Taxpayer's Reading ofrhe Stature Does nor Give Eaual Praecrion ro Public Uri/fries 'fhe PSC tax rate on public utilities depends on the ratio of the net income of the public utility company to its gross income. HRS § 239-9. During the Relevant Period, the public utility rate could not be less than 5.885 per cent, unless it was the public utility business' first year.' ]d. ' 1f the operation and the business commenced after the commencement of a calendar year, the PSC tax rate v.~as 4 per cent but only for that year. HRS b 239-9. 95182 2.DOC ] 0 ]f'Taxpayer's reading of the term "gross income" in HRS § 239-2 is given effect, "Paxpayer would be subject to a lower 4.0% genera] excise tax despite the fact that it, too, is a "public utility." Under the Taxpayer's reading of the statute, the Department of Taxation must treat private sewer companies moreSavorably than all the other public utilities and potentially violate the Equal Protection Clause. 4 Unconstitutional Reading o(a Stature Must be Avoided Legislative acts are not to be held invalid; unconstitutional, or unconscionable, if such construction can be reasonably be avoided. Kauio]ani Park Preservation Soc. v. City and County of Honolulu, 69 Haw. 569, 578, 751 P.2d 1.022, 1028 (]988). When a statute is susceptible of two constructions, one of which supports it and gives it effect, and the other renders its unconstitutional and void, the former is to be adopted, even though, the latter maybe the more natural interpretation of the language used; for an act is never to be construed as unconstitutional if a reasonable construction can be placed upon it which will render it valid. Pan American Airways Co. v. Godbold, 36 Haw. 170, ] 82 (1942). Where an otherwise acceptable construction of a statute would raise serious constitutional problems, the court will construe the statute to avoid such problems unless such construction is plainly contrary to the intent of Congress. Matsuda v. VJada, ]28 F. Supp. 2d 659. 665 (D. Haw. 2000) quoting dward J. Debartolo Corp. v. Florida Gulf Coast Blde. & Constr., 485 U.S. 568, 575, 108 S.Ct. ] 392 (1988). This approach not only reflects the prudential concern that constitutional issues not be needlessly confronted, but also recognizes that Congress, like this Court, is bound by and swears an oath to uphold the Constitution. The courts will therefore not lightly assume that Congress intended to infringe constitutionally protected liberties or usurp power constitutionally forbidden it. 95182 2.DOC ] I 1d. This "cardinal principle has for so long been applied by this Couri that it is beyond ,debate." ]d. in the present case, the constitutional problem maybe reasonably avoided if Taxpayer, a public utility, is subject to the same tax treatment as al] other public utilities. As discussed above, such construction of the statute is in accord with the intent of the legislature. C. ]ncompatibility \O~ithin HRS § 239-2 May be Reconciled Taxpayer argues that the teen "gross income" is limited to the specified examples of gross income 9ontained in HRS § 239-2. However, the definition is prefaced with the following 1.' genera] language: § 239-2. Definitions. As used in this chapter unless otherwise required by context:... "Gross income" means the gross income from public service company . Under the rule of statutory construction of ejusdem generis, where words of general description follow the enumeration of certain things, those words of general description aze restricted in their meaning to objects of like kind and character with those specified. Richardson v City and County of Honolulu, 76 Hawaii 46, 74, 868 P.2d 7193, 1221 (1994) citing Jones v. Hawaiian Elec. Co.. Inc., 64 Haw. 289, 294, 639 P.2d 1 ] 03, ] ] 08 (1982). Where the opposite sequence is found, i.e., specific words following genera] ones, the doctrine is equally applicable, and restricts application of the genera] term to Chines that are similar to those enumerated. N. Singer 2A Sutherland Statutory Construction, § 47.] 7 at 274-8] (6'" ed. 2000) . The doctrine of ejusdem generis is an attempt to reconcile an incompatibility between specific and general words so that all words in a statute and other legal instruments can be given effect, all parts of a statute can be construed together and no words will be superfluous. ]f the general words are given their full and natural meaning, they would include the objects designated by the specific words, making the latter superfluous. If, on the other hand, the 95152_2 ]2 series of specific words is given its fu]] and natural meaning, the general words are partially redundant. (Citations omitted.) ]d. at 283-85. The purpose of the rule is to give effect to both the particular and general words, by treating the particular words as indicating the class, and the genera] words as extending the provisions of the statute to everything embraced in that class, though not specifically named by the particular words. Richardson at 74, 868 P.2d at 1221 citing State v. Yan. 44 Haw. 370, 376- 77, 355 P.2d 25, 29 (1960). The rule of ejusdem generis applies when the following conditions exist: (1) the statute contains an enumeration by specific words; (2) the members of the enumeration constitute a class; (3) the class is not exhausted by the enumeration;° (4) a general term follows the enumerations and (5) there is not clearly manifested an intent that the general term be given a broader meaning than the doctrine requires. Id. These conditions are met in the present case: (1) HRS § 239-2 includets specific examples of "gross income"; (2) these specific examples of"gross income" represent the gross income generated by the core public utility businesses for PSC tax purposes; (3) the specific examples do not exhaust all the Bross income generated by the public utility businesses (i.e., it does not include the gross income of private sewer companies or public utilities operating its business for "the storage and ti~arehousing of goods"); (4) the eeneral phrase "`Gross income' means the gross income from public service company business as follows precedes the specific examples of "gross income" in HRS § 239-2; and (5) given the phrase "as follows" preceding the specific examples of gross income, an intent that the general term be given a ' A "class" is a conceptual creation encompassing numerous items with similar characteristics. N. Singer 2A Sutherland Statutorv Construction, § 47.] 8 (6'" ed. 2000). Thus, s "class" is a generalization that associates items for a panicular purpose. 1d. 5 As discussed above, this condition maybe met if the opposite is true (i.e., where the specific enumerations follow the general term). See N. Singer 2A Sutherland Statutorv Construction, § 47.17 at 274-81 (6ih ed. 2000) . 951sz 2 13 meaning than the doctrine requires does not appear to be "clearly manifested." Thus, the doctrine of ejusdem generis maybe applied to reconcile the incompatibility within the definition of "gross income" in HRS § 239-2. ]n the present case, the specific types of gross income in HRS § 239-2 correspond with the core public utility businesses. For example, public utilities operating its business for "the production, conveyance, transmission, delivery, or famishing of light, power, heat, cold, water, gas, or oil" are taxed on gross income generated from "the production, conveyance, transmission, d~hivery, or furnishing of light, power, heat, cold, water, gas, or oil"; public utilities operating its business for "the transponation of passenger or freight" is taxed on gross income generated from "the transponation of passenger or freight"; etc. Based on the rule of ejusdem generis, public utilities operating its business for the disposal of sewage must similarly be taxed on the gross income generated from the disposal of sewage, its core public utility business. ]n Hawaiian Telephone, the Hawaii Supreme Coun rejected the Director's argument that the examples of gloss income "in no way restricts or limits" the preceding phrase "'Gross income' means the gross income from public service company business" contained in HRS § 239-2. The application of the doctrine of ejusdem generis in the present case does not conflict with Hawaiian Telephone because it; in fact, restricts and limits the genera] phrase to objects of like kind and character with the specific examples of gross income within the statute. D. ]n re Hawaiian Telephone Co. is not inconsistent \\~ith the Director's Position Taxpayer heavily relies on ]n re Hawaiian Telephone Co., 6l Naw. 572, 608 P.2d 383 (1980). Hawaiian Teleohone does deal with the definition of"eross income"; however; it is clearly distinguishable from the present case. - 95 ] 82 ?.DOC 14 ]n Hav~~aiian Telephone, Hawaiian Telephone paid PSC tax on revenue from the transmission of telephone messages, but did not pay PSC tax on certain telephone directory revenues. The court framed the resolution of the case on "whether the definition of 'gross income from ...the conveyance or transmission of telephone messages or the furnishing of facilities for the transmission of intelligence by electricity' includes, or can be reasonably construed to include Hawaiian Telephone's directory revenues." Hawaiian Telephone at 579-80, 608 P.2d at 388. The court found the directory revenue non-taxable under the PSC tax. The court's opinion includes the following reasoning: ~t does not follow absent speciTc statutory authorirv shot revenues earned by Dublic service companies should be taxable under Chonter 239 merely because the activities from which they were Qenerated are Hart of or incident to Dublic service company business. Furthermore, it would not, in the case at bar, be proper for this court to venture beyond the plain language of the statute to determine whether it can reasonably be construed to include the receipts in controversy, since we fail ro discern any ambi2uirv in the Iangua¢e and we are not convinced that a literal oDDlication would lead to an absurd result. (Emphases added.] Hawaiian 7elenhone at 584, 608 P.2d at 391. ]n the present case; the issue is not a matter of whether income generated as apart ojor incident" to public utility business is subject to PSC tax; rather, the issue is a matter of whether the income generated from the core of the public utility business is subject to public utility business. Unlike Taxpayer, Hawaiian Telephone filed and remitted payment for PSC tax for income generated by its core public utility business (telephone services). Further, HRS § 239-2 expressly provides "unless otherwise required by context." In Hawaiian Telephone; context did not require a different result. The Hawaii Supreme Court in Hawaiian Telephone specifically found that there was no ambiguity and the literal reading did not lead to an absurd result in Hawaiian Telephone. ]n Hawaiian Telephone, it was undisputed that the income generated from the core public utility business was subject to PSC tax. ]n the 95]82 2.DOC 15 present case, none of the income generated from a public utility would be subject to PSC tax. ]t is this crucial difference that leads to the absurd result in the present case. Thus, Hawaiian Telephone is not inconsistent with the Director's position. E. The Rules of Construction on Which Taxpayer Relies do not Resolve the Incompatibility in the Present Case and Their Application is Limited Taxpayer argues that the fact that gross income of private sewer companies is not specifically identified within the definition of gross income illustrates that the legislature intended that it be excluded. This rule of construction (maxim of expressio unius esi exclusio alterius), on wh~Ch Taxpayer relies, however, exists only as an aid to statutory interpretation and its application is limited to ascertaining legislative intent that is not otherwise apparent. International Savines and Loan Association. Limited v. Wiie, 82 Hawaii ] 97, 201, 921 P.2d 117, 121 (1996). In the present case, as discussed above, legislative intent is otherwise apparent. Quoting Hawaiian Telephone, Taxpayer also argues that the rule of strict construction requires that statutes imposing taxes must be read in the taxpayer's favor. Taxpayer's Mem. in Support of its MSJ, pp. 6-8. Although not emphasized, Taxpayer's own quotation includes the following language of the court in Hawaiian Telephone: ]t is important to note, however, that the rule of strict construction with regard to taxing statutes should only be resorted to "as an aid to construction when ambiguity or doubt is apparent on the fact of the statute; and then only after other possible extrinsic aids of construction available to resolve the ambiguity has been exhausted." [Citations omitted.] See Taxpayer's 1`9emorandum in Support of its MSJ; p. 7; Hawaiian Telephone at 578-79, 608 P.2d 388. ]n the present case, other extrinsic aids of construction available resolves the ambiguity of the statute and it is unnecessary to resort to the rule. Even if these rules applied, they are inconsistent with the expressed history and structure of the PSC tax and fail to resolve the potential violation of the Equal Protection Clause. 95]82 2.DDC ]6 VI. CONCLUSION ~ ,Taxpayer generated income from its public utility business and cannot escape PSC tax liability based on a technical ambiguity in the statute. The gross income generated from Taxpayer's core private sewer company business is "gross income" subject to PSC tax. To construe the applicable statutes otherwise would mean that PSC tax on public utilities is not applicable to a member of the public utility classification. This is an absurd that (1) is inconsistent with and illogical given the history and structure of PSC tax and (2) requires the Department of ?axation to treat private sewer companies more favorably than the other public utilities and potentially violate the Equal Protection Clause. Based on the Motion, the memorandum in suppon of the Motion, and the record herein, Appellant respectfully requests that this Court grants this Motion finding that, as a matter of law, that Taxpayer's income generated from its public utility business is gross income subject to PSC tax, and/or any other relief it deems just. DATED: Honolulu, Hav.~aii, June 23, 2004. MARK BENNETT Attomey Gener(al/'~J By. ~ 2 ~s MARY H.Y. BAHNG Deputy Attomey Genera] Attomey for Appellant DIRECTOR OF TAXAT]ON, STATE OF HAWAI] 95182 2.DOC ] 7 IN THE TAX APPEAL COURT OF THE ~ STATE OF HAWAll IN THE MATTER OF THE TAX APPEAL CASE NO.02-0067 of NOTICE OF HEARING OF MOT10N AND CERTIFICATE OF SERVICE DIRECTOR OF TAXATION, STATE OF HAWAII, Appellant, vs. LA]E TREATMENT WORKS, INC., Tax a er-A ellee. NOTICE OF HEARING OF MOT10N TO: ALAN J. MA, ESQ. BRUCE D. H]ENEMAN, ESQ. Gerson & Hieneman American Savings Bank Tower, Suite 780 1001 Bishop Street Honolulu, Hawaii 96813 NOTICE 1S HEREBY GIVEN that APPELLANT D1REC?OR OF 7AXAT10N, STATE OF HAWAII'S MOTION FOR PARTIAL SUMMARY JUDGMENT FINDING THAT TAXPAYER'S INCOME GENERATED FROM ]TS PUBLIC UTILITY BUSINESS 1S GROSS INCOME SUBJECT TO PSC TAX shall come on for hearing before the Honorable Gary W.B. Chang, Judge of the Tax Appeal Court, Circuit Court of the First Circuit, in his courtroom at 777 Punchbowl Street, Honolulu. Hawaii on July ]2, 2004 at 9:00 o'clock a.m, or as soon as counsel maybe heard. 95 7 82_2. DOC CERTIFICATE OF SERVICE 1 hereby certify that on June 23, 2004, a copy of the foregoing was duly served by HAND DELIVERY addressed as follows: ALAN MA, ESQ. BRUCE D. HIENEMAN, ESQ. Gerson & Hieneman American Savings Bank Tower, Suite 780 1001 Bishop Street Honolulu, Hawaii 96813 Attorneys for Taxpayer-Appellee LAZE TREATMENT WORKS, INC. DATED: Honolulu, Hawaii, June 23, 2004. MARY H. Y. BAHNG Deputy Attorney Genera] Attorney for Appellant DIRECTOR OF TAXATION, STATE OF HAWAII ~siez z.DOC 2