HomeMy WebLinkAbout03/09/2004 - Study SessionCITY OF NEWPORT BEACH
City Council Minutes
Study Session
March 9, 2004 - 4:00 p.m.
ROLL CALL
Present: Heffernan [arrived at 4:15 p.m.], Rosansky, Adams, Bromberg, Webb,
Nichols, Mayor Ridgeway
Absent: None
CURRENT BUSINESS
1. CLARIFICATION OF ITEMS ON THE CONSENT CALENDAR — None
2. DISCUSSION OF BUSINESS LICENSE REQUIREMENTS/
PROCEDURES.
Mayor Ridgeway explained that he received a request for a new license from the
Revenue Division today, which he opposes, on an LLC that has property in
northern California and the only thing that is generated from his office is a tax
return. He requested an opinion from the City Attorney on whether he could
weigh in on this issue or if it would present a conflict. City Attorney Burnham
explained that since this is only a discussion item and no action will be taken, he
can participate in the discussion.
Revenue Manager Everroad explained that the notices weren't sent out in
anticipation of this presentation. Mr. Everroad explained that at the EDC
meeting they presented evidence from the original business license tax register
dated 1906 which indicated that the City began licensing businesses just shortly
after incorporation. The amounts paid in 1906 would be similar to what is being
paid today if they're adjusted for inflation. The authority under which the City
imposes business license taxes is pursuant to the Charter. The City Council
adopted Chapter 5.04, the business tax ordinance, which requires business
licenses for revenue purposes only. It is very specific that it is for revenue only
and not for regulation — it is a tax assessment. It is also not related to the costs
to process business licenses (new applications, renewals, the cost of enforcement,
discovery costs, etc.). The City does regulate many businesses by different
ordinances such as massage, vacation rentals, pawnbrokers, taxis, etc. The
charges associated with those licenses are regulatory in nature and the City
recovers just the cost of processing those applications and issuing the permits.
The City collects a lot of information about businesses and provides that
information to a variety of individuals and entities. The City also receives a lot
of calls from the public about particular businesses to determine if the business
is licensed. Other entities that the information is provided to are law
enforcement, other City departments, courts, tax agencies (Franchise Tax Board
(FTB), Internal Revenue Service (IRS), and the Board of Equalization (BOE)), as
well as regulatory agencies. The business license tax generated about $2.6
million in revenue in the last calendar year and the rates were last set in 1993.
He explained the breakdown of the current rate structure as imposed by the
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City's ordinance. Referring to a chart listing the licenses by category he noted
that 29% of the businesses are based in commercial locations without sales tax I
and there are about 14% of the businesses in commercial locations that do
produce sales tax. There are 29% based out of town and another 29% at
residential locations within the City. He explained that each year
approximately 25% of the businesses are new, which are new businesses to the
community — about 25% of that inventory is being replaced. About 50% of the
businesses renew their licenses on an annual basis, about 11% cancel and last
year there was about a 15% non - renewal rate. The 15% will either eventually
fall into either the cancelled license category or become an enforcement effort for
the field inspectors and will eventually probably fall back into the renewed
license category. He noted that the City issues about 4500 new business licenses
every year. Mr. Everroad stated that the NBMC defines "business" as arts,
professions, trades and occupations in all and every kind of calling, whether or
not carried on for profit. The definition went around through communities in
the 1960s and it hasn't evolved much since that time. He noted that this is an
issue they struggle with all the time and provided an example of homeowners
who pull sellers permits from the BOE in order to access the wholesale houses
for purchases for their homes. He explained that state law would require the
person to be actually actively involved in business to hold the seller's permit,
however thousands of people annually pull these permits and therefore
hundreds are contacted by the Revenue Division regarding business license
permits. The City law also requires that a separate license be obtained for three
types of situations: 1) every separate location; 2) each separate type of business;
and 3) each separate business entity. He further explained how the City
interprets this provision of the law and the way the City determines who fits
into each of these situations. Mr. Everroad explained that two years ago the
legislature clarified for local tax purposes what is within the City's purview to
license. State law, Business & Professions Code Section 16300, effective 2002,
says that a city or county may not impose a business license on an employee. He
noted that making this determination used to be a rigorous exercise because
they had a 32- question standard that was applied by the IRS to determine
whether the individual performed services as an employee or as an independent
contractor. If performed as an employee then they're not subject to the tax. If
they are an independent contractor and not an employee they are subject to local
tax for business tax purposes. He stated that the law also clarified that when
there is a dispute between a city and a taxpayer the manner in which the
taxpayer reports income to the FTB or IRS creates a presumption for local tax
purposes. He added that the NBMC exempts certain types of businesses and
there are federal exemptions and state exemptions. The local exemptions are
limited to anything the federal or state governments exempt and minors who
generate less than $800 annually, artists who generate less than $1000 in gross
annually and residential rentals if there are less than three residential dwelling
units. In response to issues raised by Mayor Ridgeway and Council Member
Heffernan, he explained how the City determines who they target for noticing
purposes. In response to Council Member Heffernan, Mr. Everroad explained
that the City does not impose a fee on business so there is no correlation
between the level of services provided to that business and the amount of
business tax imposed. He noted that a lot of cities impose a processing fee for
enforcement, processing of renewals, etc., however Newport Beach does not. He
reiterated that the City's charge is a business tax and there is no relationship
between the amount of services that a particular business receives and the
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amount of tax they pay. Mr. Everroad noted that about one -third of the business
license revenue comes from the staffs efforts in discovering and applying the
municipal code requirements for businesses. He explained that there are two
inspectors that perform the work and their jobs are generally discovery,
notification and enforcement. He indicated that they receive information from a
wide variety of sources: citizen complaints and queries, Employment
Development Department, State Board of Equalization, Orange County Health
Department, fire inspection records and from the Franchise Tax Board. The bill
(AB63) that authorized the City to receive this information on tax filers was a
sister bill to the bill that limited the cities ability to tax employees and when
there are disputes to use how the taxpayers filed as the presumption on whether
or not the taxpayer is a business or an employee. He explained that based on
the type of return filed the FTB determines whether it is a business entity and
then communicates that information to the City. The City then adds that
information to all the other sources and starts targeting the businesses based on
the greater number of indicators that a business might have. In response to
Mayor Ridgeway he indicated that the taxpayer receives a letter notifying them
of what the City believes the tax liability is for the business and also
communicates to the business greetings and welcomes them to the community.
He explained that they try to communicate to the business entity the tax
obligations of the City and ask them to communicate with the City if they have
some issues associated with the notice. He stated that they produce
approximately 6000 notices annually to the various entities through the various
sources of discovery. He stated that they get business "white" listings of entities
who have represented to the phone company that they are a business and want
to be listed as a business. He said the information isn't a very reliable source of
nexus for the City in terms of business conduct; however the FTB and IRS
information is a far more reliable source of discovery and a far greater indicator
of business conduct. He noted, however, that they realize that those businesses
are not necessarily located in Newport Beach. He indicated that they provide a
website, a phone number, and contact information for the taxpayer to
communicate their particular situation with the City. He explained that the
first notice is a request and the City administratively waives the penalties and
knows from the information from the FTB that the business has been in
existence since at least 2001, however doesn't know if it has been in Newport
Beach all that time. He said the business license tax ordinance also provides for
penalties for not registering with the City in a timely fashion. If no response is
received the second notice is a little more forceful and explains the implications
of non - compliance. He further explained that their enforcement efforts are to
respond to taxpayers telephonically, and by mail they identify and contact non-
responders, issue administrative citations or court citations depending on the
situation. Mr. Everroad pointed out that since the early 1960s the ordinance has
provided that anyone aggrieved by the business tax ordinance and the decision
by the Finance Director to impose a business license tax can be appealed to the
City Council. He noted that he's been in business licensing since 1986 and has
never brought a business tax issue to City Council on appeal. He said they don't
get anywhere close to noticing even half of the number of businesses that
information is received about each year. The noticing of businesses is prioritized
based on those that have the largest number of indicators of business conduct
and the most reliable source of indicators of business conduct. He noted that
unfortunately the taxpayers are contacting council members before taking
advantage of the invitation to contact staff about their issues and reiterated that
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the City is not interested in taxing ownership entities with no physical presence
in the community beyond a tax filing with the FTB.
Council Member Bromberg stated that he is also peppered with questions about
this and on one occasion he referred the Balboa Island Art Walk to Mr. Everroad
and he resolved the issue with them. He voiced concerns with vendors that
come into the City for an event and give their wares away and the City makes
them buy a business license. Mr. Everroad explained that it depends on the
amount of business presence in the City and noted that staffs interest is on
those businesses that are conducting business. He said it is not the City's
practice to apply business licenses to someone giving away free product at a
special event. Council Member Bromberg indicated that he is working with the
organizer for the Newport Beach Triathlon, which this year will be solely in
Newport Beach, and was told that every year their vendors giving away
products are taxed. He also indicated that he was told that the two Tall Ships
that came into Newport Harbor were charged $1800 in business license taxes
and they are non -profit and 100% educational. Mr. Everroad explained that the
City imposes a Marine Charter passenger tax and a charter permit fee for
charter vessels. He said he believed that the two vessels identified inquired
with the Nautical Museum about what the requirements are related to running
charters out of that particular location. The director made contact with staff
about permit requirements, business license requirements and charter tax
requirements. In sum, they may have gotten to $1800 based on the number of
passengers, and the number of charter operations that they proposed to conduct,
etc. Council Member Bromberg noted that 80% of the passengers were kids, it
was an educational event and they were being charged per student. Mr.
Everroad explained that the charter tax is based on the per ticket charge for
access to the charter vessel and if the charge is less than $26 per passenger,
there is no tax applied. He indicated that he isn't aware if they even applied for
permits, however he stated that he would look at the charges. Council Member
Bromberg said that if the City is interested in making itself more business
friendly, then the City should do everything possible to make it so. He noted
that one way to do that would be to re- evaluate the City's position regarding
one -day events, make special dispensation for educational functions, and also
look at non -profit and possibly give them a sliding scale fee. As far as the LLCs,
he said if something takes business away from Newport Beach, whether the City
gets income from the business or not, in his mind that isn't the primary
requirement. In response to Council Member Nichols' questions about
corporations, Mr. Everroad explained how the City determines who should be
noticed and stated that the City doesn't know what the level of business
presence in the community the LLC or corporation might have until they contact
the City. He stated that the largest target is the businesses with the greatest
amount of indicators.
Mayor Ridgeway read the letter he received from the City and indicated that he
doesn't feel it is unfriendly, however he does feel it is intimidating. He noted
that the letter doesn't invite him to call the City unless he is licensed in Newport
Beach, but pushes him off onto the FTB. He stated that the letter doesn't
address appeal rights and basically just says fill out the form and send in the
money. Mr. Everroad responded and pointed out that the letter does guide the
party receiving the letter to the City's website, provides a phone number and the
inspector's name if they need more information. He further explained that state
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law prohibits the City from dealing with `net' business conduct and only allows
the City to deal with `gross' business conduct. He stated that based on their
prior experience they try to answer as many questions as possible in the initial
contact with the taxpayer.
Mayor Pro Tem Adams stated that he feels the letter is okay and said he feels
the City is doing exactly what it should be doing based on the code. He
questioned whether it would make sense to hire additional staff and whether
there would be a rate of return if the City invested in another employee. He
stated that he feels it is unfair to the people that are paying business license
taxes if there is half a million dollars worth of business license tax that isn't
being collected. As it relates to staffing, Mr. Everroad reported that the City has
historically spent so much time on processing the thousands of leads that staff
recently automated that process and in the last year have gone from about 3000
notices to more than 6000 notices. Automating the process creates efficiencies
that enable the inspectors to be more effective in the enforcement efforts and
spend less time on the discovery and cross - referencing efforts. He suggested
that he feels the City is getting where it needs to be in terms of the application
of the ordinance and contacting those that are subject to the tax.
Council Member Heffernan stated that if he has all these LLCs, he'll broadcast a
warning in his update to the residents that they may not want to do business in
the City because they could be hit with a $400 tax for each one. He stated that
there is no nexus in what he does in the City for owning a piece of real estate out
of state and is just the fiduciary. He said he feels it's a fair assessment for
people to know they're going to be hit for this tax. Mayor Pro Tern Adams
cautioned him about broadcasting such information when it is still uncertain
whether these people will be liable for business tax until they contact the City to
find out if it meets all the legitimate requirements. He noted that the whole
premise of business tax is that there is not a nexus between them and what
service they are provided.
City Attorney Burnham reiterated that the business license ordinance has been
in effect since the City's incorporation, the current version was adopted in 1977
and has been updated on a regular basis. He stated that it has been updated
largely because Mr. Everroad is one of the recognized experts on business license
taxes in the state and goes to Sacramento to testify and is very much involved in
the whole enforcement process, as well as other areas. He pointed out that what
Mr. Everroad is doing is enforcing an ordinance the City Council adopted. If the
City Council believes that there may be areas of the ordinance that require some
modification, then staff would look into those. He said staff would not want to
make amendments that emasculate the ordinance or create the potential for
litigation on the basis of equal protection concerns. As far as the letter, he said
he thinks maybe it can focus on the need for or the desirability of the person that
receives that notice to contact the Business License Division and clarify the
situation. He stated that his experience with referring people to Mr. Everroad is
that he handles them extremely well and in a very business - friendly way. He is
enforcing the ordinance as he is charged to do. He noted that the letter can be
modified slightly so it still conveys the essence of the information that should be
conveyed so everyone understands what the issues are and encourages them to
contact the Business License Division to resolve the issues.
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Council Member Heffernan stated that as a business planner he would probably
set up a post office box in another City so he wouldn't get any notices and have
more hurdles to deal with. Mayor Pro Tem Adams pointed out that the law
applies to all cities and he would still receive a letter even if the address were a
P.O. box.
Mayor Ridgeway stated that he agrees with some of Council Member Bromberg's
comments, however stated that he feels there is abuse by some of the 501(c)(3)'s,
but there is a potential for changes for one -day events. Mr. Everroad pointed
out that the City's ordinance does currently exempt 501(c)(3)'s from the business
license tax, so if the Tall Ships are operating as a non -profit organization they
would not be subject to the tax. He reiterated that staff is only applying the
current existing provisions of the ordinance. He noted that there may be an
opportunity to improve on those and staff is happy to follow Council's direction.
He reported that the City generally licenses 50% of the businesses on the first
notice they receive. He further pointed out that those that aren't subject to the
business license tax and have contacted the City, in subsequent tax filings, they
won't receive additional notices. The account is coded to identify that the
taxpayer has been communicated with and staff does not believe they are
subject to the business license tax. Mayor Ridgeway requested that staff follow -
up with a memo to all of Council answering the questions and concerns raised by
Council Member Bromberg.
Council Member Nichols reported that he hires sub - contractors in his
engineering business and they are paid as such and some of the work is done in
his office and some in their own offices. He questioned how they would be
treated and would they be required to have a business license in Newport Beach.
Mr. Everroad reported that if their home office is located in Newport Beach and
the City is aware of it, they will be approached by the Business License Division.
If they go to his home office and conducted some measure of business at that
home office, the City would rely on the source of discovery to determine the tax
liability.
Mr. Everroad reported that the last time this issue was before Council was in
1993 for a rate adjustment. He introduced his two inspectors — Casey Cooper
and Monique Navarrete.
3. SPECIAL EVENT PERMIT PROCESS REVISIONS.
Recreation and Senior Services Director Knight stated that staff is here today to
get some direction from Council on some items dealing with the special event
permit process — revisions to the code and proposed fee revisions. Using a
PowerPoint presentation, Ms. Knight explained that prior to 1995 the permits
were processed in the Revenue Division. Since the Recreation Department took
over the processing in 1995 the permits have increased in complexity and the
number of permits applied for. In 2001 the department hired a Special Event
Coordinator who oversees all the permits, the processing of the permits and
works with all the departments involved. In 2001 a committee was formed to
address changes in the process. She explained the process that was used prior
to the hiring of the coordinator. The committee is comprised of different
department representatives that oversee or enforce or have some sort of
regulatory oversight in the process. Over the last couple of years the committee
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has been working to add more definition to the process, streamline it so it's
easier for the applicant and to have a more coordinated process between the
different departments. A consultant was also hired to look at the current
ordinance and to help staff re -write it so it is more defined and there are more
enforcement areas. She explained the current application process. Through
this process, she explained that the committee has come up with some revisions
as outlined in the staff report. One of the recommendations is to revise the code
to provide greater detail, descriptions and definitions. Also through this process
she stated they have identified two types of permits, the review procedures have
been enhanced, the appeal process has been expanded, clean -up deposits has
been added, and damage reimbursements has been addressed. She stated that
in the new code staff is proposing two types of special event permits. The first
would be for a one -time event which is a good percentage of the requests that
are received. The second type of permit, a Bundled Type Permit, will address an
area that has been increasing in the past couple of years. These permits will be
for multiple events that are similar in nature at one location in one year. Using
weddings as an example, she stated that the venue would pay for one fee for up
to 20 similar events in a year and once they have used those 20 events, they
would come back for renewal. Those events would still be tracked, however the
paperwork and processing for staff would be cut down and the processing for the
applicant is more streamlined. Ms. Knight explained that part of what the
committee has done is streamlined the levels of the special event permits from
four to three, making it easier to determine the proper category and level for
each event. The levels determine what level of monitoring is needed, what level
of City staff support is needed, and the fees involved. Another area that the
committee looked at was the cost recovery. Currently the code sets the recovery
at 36% of the staff costs. The committee is proposing that the fees be increased
for resident special event permit applications to 50% of the total staff costs and
for a non - resident permit application 100% of the total cost to process, monitor
and enforce the permit. Ms. Knight reported that the estimated cost to process
a special event permit depending on the level is based on staff time to review
and route the permits. Referring to the chart she pointed out what the current
fees are for each of the three levels, as well as the proposed fees, and noted that
currently there is a differential for residents and non - residents. Mr. Burnham
stated that the City is allowed to charge different fees for residents and non-
residents. For the bundled permits she said the fee for up to 20 events would be
up to $2000. She noted that this process will take less staff time, less time for
the applicant and the fees will be reduced because of the staff time that is saved.
Based on the number of permits issued in 2003 and what is anticipated with the
proposed system, Ms. Knight noted that staff will be processing less permits
because she anticipates bundling about seven permits for certain venues such as
the Dunes, Hyatt, Orange County Museum of Art, etc. Under the old fee system
the City raised $52,400 and under the new proposed fee structure it would
generate $71,000. She indicated that staff is looking for direction on the
proposed changes to the ordinance, the cost recovery percentages and the
proposed fees.
Mayor Ridgeway questioned whether any exceptions have been created for
501(c)(3)s or appeal rights. Ms. Knight reported that exceptions have not been
created for them and currently there is no process in place for someone to ask
for the fees to be waived. She noted that the proposed ordinance would give the
City Manager discretion, based on certain circumstances, to waive a fee. She
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said there isn't anything in the process to allow the City to waive the fee for one
activity that another activity would be charged for.
Council Member Webb confirmed that events such as the Race for Life, Spirit
Run and Harbor Heritage Run are charged fees even though they are charitable
events. He noted that a lot of staff time goes into reviewing and issuing the
permits and stated that the City has to be really careful when consideration is
given to waiving these fees. Mayor Pro Tem Adams concurred with Council
Member Webb about waiving fees. In differentiating between residents and
non - residents Ms. Knight explained that staff has become more diligent in
asking for proof of residency (utility bills, etc.). As far as entities the new
ordinance states that if you are a business and are applying as the business for a
special event permit and the business is in Newport Beach, then it is a resident
rate. She noted that last year at Level 1 there were 245 resident permits and 16
non - resident permits issued and overall there were 272 resident and 27 non-
resident permits issued. Ms. Knight reported that last year the fees were
increased slightly because in some areas less than 36% was being charged and
prior to that the fees were increased in the early 1990s.
Staff was directed to bring this item back to a Regular meeting for Council
consideration.
PUBLIC COMMENTS - None
Mayor Ridgeway identified the real property described in CS -4 of the Closed Session
agenda (1971 Mesa Drive and 20401 Acacia Street) as a topic to be discussed in Closed
Session.
ADJOURNMENT - at 5:32 pan.
The agenda for the Study Session was posted on March 3, 2004, at 2:45 p.m. on
the City Hall Bulletin Board located outside of the City of Newport Beach
Administration Building.
Recording Secretary
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Mayor
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