HomeMy WebLinkAbout5.1 Viacom Possessory Interest Tax CITY OF DUBLIN
AGENDA STATEMENT
CITY COUNCIL MEETING DATE: August 26, 1991
SUBJECT: Written Communication from Viacom Cablevision regarding
Alameda County Assessment of Property Tax
Report prepared by Paul Rankin, Assistant City Manager
EXHIBITS ATTACHED: 1 ) Letter dated August 7, 1991 from Michal Dittrich,
Government Affairs Manager
2) Draft Letter to Board of Supervisors
RECOMMENDATION: Oxonsider request
FINANCIAL STATEMENT: Company anticipates a $1 .50/month rate increase in
addition to any other operating cost increases as
a result of the action by the County Assessor.
DESCRIPTION: Pursuant to Federal Law, the City has no authority to
regulate cable television rates. Congress has enacted legislation which
allows operators to charge whatever the market will bear. Viacom has
requested the City's support in an appeal of a property tax assessment
being levied in Alameda County. The taxes paid by the company are
considered operating expenses which are eventually passed on to the
consumer.
Basis For Issue
In 1987, Viacom went through a merger which was deemed a change of
ownership. During any change in ownership under California Law, a
reassessment of the company's property holdings is undertaken by the County
Assessor. This reassessment is not any different than a property owner who
sells their property. Typically, a transfer would involve two different
parties and therefore, the seller would not be familiar with the amount of
increase in the tax bill received by the buyer. In addition to property
tax on buildings owned by the firm, the company also pays a "possessory
interest" tax. This provision recognizes an interest in real property
which exists as a result of the exclusive use or right to possession which
is not accompanied by title ownership of property. Viacom has a franchise
which grants them the right to operate within the public streets and right-
of-way. The current franchise runs through December 31 , 2000.
The appraisal of a firm's possessory interest is not as clean cut as the
appraisal of real property. For example, the Assessor cannot review recent
transactions to determine a comparable value. The State Board of
Equalization publishes proposed methods of appraising assets of cable
television companies. Viacom used one of the three approved methods to
calculate their estimated taxes. Rates have been based upon an assumption
that one of these methods would be used. Viacom representatives have
indicated that the Assessors in several California counties in which they
operate have developed their own methodology, instead of choosing from the
standard methods published by the State Board of Equalization.
Staff has discussed the issue with Mr. John Scott, the Alameda County
Assessor. It is the Assessor's position that the State Handbook is only a
guideline and not the only method available. The County Assessor indicated
that all utilities are appraised by the State Board of Equalization;
however, cable television franchises are not regulated as utilities and
therefore the assessment is up to each County Assessor to determine the
appraisal. Mr. Scott also stated that his office currently has pending
appraisals on 6 other cable television franchises. Four of the
reassessments are due to a change in ownership and 2 are due to the
negotiation of a new franchise. He indicated that the methodology used to
develop the value of the possessory interest included the firm' s income,
number of subscribers and other factors.
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COPIES TO: Michal D' ., -
ITEM NO. jf OA& Cable isio,, 1 T Y CLERK
FILE 1 /101 0 0
Impact of Alameda County Assessment
The impact on the local franchise is that the assessed value upon which
Viacom's possessory interest tax is calculated will be $65.6 million,
compared to the 1987 assessed value of $1 .2 million. Viacom has indicated
that they did assume that some sort of assessment would occur, however,
they consider the Assessor' s action excessive. This amounts to a 5,003%
increase. The increase anticipated by Viacom was consistent with the
methods developed by the State Board of Equalization.
Ms. Myrt Jones, Viacom General Manager, indicated that the impact has
resulted in substantial changes to Viacom's 1987 property tax bill. The
following figures include both Possessory Interest, as well as other assets
combined: Pre-1987 Alameda County Property Taxes - $151 ,900; 1987 Property
Taxes Due after Reassessment - $945, 100
Impact on Rates
Viacom representatives have indicated that they anticipate a $1 .50 per
month rate increase as a result of this action. This amount is
independent of any additional general rate increase. Company
representatives have verbally stated to City Staff that if the entire
amount attributable to the tax increase were passed on, the necessary
increase would be $4.50 per month.
Viacom's position is that they intend to pay the tax as required and then
pursue legal and administrative appeals. In the event that this action is
successful, Viacom would then make appropriate adjustments.
It is important to note that seeking relief will also require Viacom
resources, which in all likelihood the cost for attorneys and others will
be recovered through the rates. Of course, in the event of a dispute and
actual litigation, the County will also incur certain costs. In the event
that a negotiated settlement is not reached, Dublin rate payers will
contribute towards legal costs of both sides in the dispute. The County
Assessor's legal costs would be paid by taxpayers and Viacom' s legal costs
will presumably be passed on to the rate payers.
Viacom Request
Viacom has requested that the City request that Alameda County repeal the
excessive assessment and select from the methodologies identified in the
State Board of Equalization Handbook, as it relates to cable television.
Staff has prepared a draft letter to the Board of Supervisors based upon
the request.
It is recommended that the City Council consider the request. y
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AU G 8 1991
IT/ViacomCablevision
August 7, 1991
Richard C. Ambrose
City K-Hager
City of Dublin
P.O. Box 2340
Dublin, CA 94568
Dear City Manager Ambrose:
In 1987 Viacom went through a merger, currently deemed to be a change
of ownership, which triggered a reassessment of our property in the
cen California counties in which Viacom operates. Anticipating this
:reassessment, Viacom created a reserve to pay the expected tax in-
crease, using the traditional appraisal methods outlined in the State
Board of Equalization's Handbook on Cable Television, as they have
been previously applied to us. Viacom was prepared to absorb this
expected increase in property tax as a cost of doing business. How-
ever, the recently completed appraisal resulted in a 5707. increase in
the combined property tax bills for Viacom's California operations in
1987, with further increases frcxn 1988 and beyond.
The bulk of the increased assessment is for "possessory interest",
which taxes Viacom's use of public rights-of-way. For example, the
appraised value of Viacom's possessory interest in California for 1987
went from $18.5 million to $506.0 million, an increase of over 27 times.
This is an exLraord:-easy increase, even in California's inflated real
property market. Further, cn top of this tax, Viacom already pays
a franchise fee for the same right to use public rights-of-way.
This excessive tax is beyond what Viacom can absorb; therefore, we antic-
ipate a significant increase in cable rates on October 1, 1991. We
believe the Assessors acted arbitrarily in their valuation methodology.
By accepting the valuation prepared by the Alameda, Contra Costa, Marin,
San Francisco and Sonoma appraisers, your Assessor has endorsed a radical
new method of valuation.
State law requires that Viacom pay the increased tax even though we
believe it to be excessive and plan to challenge it.
6640 Sierra Lane,Dublin,CA 94568 4151828-8520
V
City Manager Ambrose.
August 7, 1991
Page 2
Therefore, Viacom will pay the additional tax, including back taxes
commencing in 1987, and then seek relief through administrative
appeals and court action.
We are truly outraged by being forced into this property tax and
rate increase and Viacom pledges to exhaust every possible remedy
to overturn this unfair and dubious tax assessment. We intend to
make appropriate adjustments after all taxes are paid and costs
are recovered, should we prevail.
We ask your assistance in appealing to the Alameda County Board of
Supervisors and the Assessor to repeal this grossly unfair reassess-
ment. I am hereby requesting that the City Council send a resolu-
tion to these elected officials asking them to reconsider the
Assessors valuation methodology to reflect the approved State Board
of Equalization Handbook method for property appraisal as it relates
to Cable Television.
Sincerely,
Michal Dittrich
:tanager, Governmm*_ Affairs
MD/jwc
ti
August 27 , 1991
The Honorable Mary King, President
and Members of the Board of Supervisors
County of Alameda
1221 Oak Street, Room 555
Oakland, CA 94612
Subject: Calculation of Property Tax Assessment for Viacom
Cablevision
Dear President King and Board Members:
The purpose of this letter is to request assistance from the
Board of Supervisors in reviewing the methods used by the County
Assessor to reassess Viacom Cablevision property after a 1987
merger. This letter is being directed to you following
consideration and input by the Dublin City Council at their
meeting on August 26, 1991.
In 1987, the assessed value upon which Viacom's possessory
interest tax was calculated in Alameda County was $1.2 million.
As a result of the merger, the company anticipated that a
reassessment would occur, based upon one of the traditional
methods identified in the State Board of Equalization's Handbook
on Cable Television. Instead, the Alameda County Assessor has
relied upon a new method of valuation, not shown in the State
Handbook. This action results in a new assessed value for
possessory interest tax purposes in Alameda County of $65. 6
million. This is an increase in assessed value of over 5, 003%,
and is not based on the methods identified by the State Board of
Equalization Handbook.
The company has advised the City Council that this will result in
significant rate increases to residents receiving this service.
The Board Members should be aware that the Valley cities are in a
difficult location to receive regular television signals. In
most of Dublin, it is impossible to receive television reception
without cable service. Unnecessary tax increases will further
impact our residents access to regular news and entertainment
services provided by cable television.
The City of Dublin concurs that a reassessment is appropriate,
however, alternative methods need to be explored. If litigation
to appeal the assessment is the only option available, our
residents will lose twice since in all likelihood they would be
contributing toward expensive legal costs for both sides. It
would appear that the Board of Supervisors could undertake a
leadership role in rectifying the current situation. Given that
there have been published guidelines developed by the State Board
of Equalization, we would support using one of the traditional
methods.
v
The Honorable Mary King, President
and Members of the Board of Supervisors
Page 2
On behalf of the entire City Council, we appreciate your
consideration of this important matter.
Sincerely,
Peter W. Snyder
Mayor
cc: John Scott, Alameda County Assessor
Steve Szalay, Alameda County Administrator
Mayors of Livermore, Pleasanton & San Ramon