HB 7 - Intangible personal property tax; repeal

Georgia House of Representatives - 1995/1996 Sessions

HB 7 - Intangible personal property tax; repeal

Page Numbers - 1/ 2/ 3/ 4/ 5/ 6/ 7/ 8/ 9/ 10/ 11/ 12
Code Sections - 48-6-20/ 48-6-21/ 48-6-22/ 48-6-23/ 48-6-24/ 48-6-25/ 48-6-26/ 48-6-26.1/ 48-6-27/ 48-6-28/ 48-6-29/ 48-6-30/ 48-6-31/ 48-6-32/ 48-6-33/ 48-6-34/ 48-6-35/ 48-6-36/ 48-6-37/ 48-6-38/ 48-6-39/ 48-6-40/ 48-6-41/ 48-6-42/ 48-6-43/ 48-6-44
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1. Buck  135th

House Comm: / Senate Comm: / House Vote: Yeas Nays Senate Vote: Yeas Nays ---------------------------------------- House Action Senate ---------------------------------------- ---------------------------------------- Code Sections amended: 48-6-20, 48-6-21, 48-6-22, 48-6-23, 48-6-24, 48-6-25, 48-6-26, 48-6-26.1, 48-6-27, 48-6-28, 48-6-29, 48-6-30, 48-6-31, 48-6-32, 48-6-33, 48-6-34, 48-6-35, 48-6-36, 48-6-37, 48-6-38, 48-6-39, 48-6-40, 48-6-41, 48-6-42, 48-6-43, 48-6-44
HB 7 LC 18 6388 A BILL TO BE ENTITLED AN ACT 1- 1 To amend Chapter 6 of Title 48 of the Official Code of 1- 2 Georgia Annotated, relating to taxation of intangibles, so 1- 3 as to repeal the intangible personal property tax; to 1- 4 provide an effective date; to repeal conflicting laws; and 1- 5 for other purposes. 1- 6 BE IT ENACTED BY THE GENERAL ASSEMBLY OF GEORGIA: SECTION 1. 1- 7 Chapter 6 of Title 48 of the Official Code of Georgia 1- 8 Annotated, relating to taxation of intangibles, is amended 1- 9 by striking Article 2, relating to the intangible personal 1-10 property tax, which reads as follows: "ARTICLE 2 1-11 48-6-20. (Index) 1-12 As used in this chapter, the term: 1-13 (1) 'Bank' means any financial institution chartered 1-14 under the laws of this state or under the laws of the 1-15 United States and domiciled in this state which is 1-16 authorized to receive deposits in this state and which 1-17 has a corporate structure authorizing the issuance of 1-18 capital stock. 1-19 (2) 'Collateral security loan' means a loan held by any 1-20 broker which represents credit extended in connection 1-21 with the purchase or sale of stocks, bonds, or other 1-22 securities of a like character held as collateral 1-23 security for the loan. 1-24 (3) 'Depository financial institution' means a 'bank' 1-25 and a 'savings and loan association.' 1-26 (3.1) 'Domesticated foreign corporation' means: 1-27 (A) A foreign corporation which, prior to April 1, 1-28 1969, has domesticated in this state under the -1- (Index) LC 18 6388 2- 1 procedure available prior to that date and which was a 2- 2 domesticated foreign corporation on that date; or 2- 3 (B) A foreign corporation which has procured a 2- 4 certificate of authority to transact business in this 2- 5 state from the Secretary of State and which maintains 2- 6 its corporate headquarters in this state. 2- 7 (4) 'Money' means specie, currency, and credits 2- 8 resulting from the deposit of money, currency, checks, 2- 9 bills, and other evidences of the credits. 2-10 (5) 'Restricted foreign intangibles' means all 2-11 classifications of intangible personal property acquired 2-12 and held in a foreign country incident to the conduct of 2-13 the business of insurance within the foreign country if 2-14 the intangible personal property is held in the foreign 2-15 country pursuant to laws or regulations of the foreign 2-16 country or administrative guidance by the government of 2-17 the foreign country which prohibit or restrict the 2-18 transfer of said property outside of the jurisdiction of 2-19 the foreign country. 2-20 (6) 'Savings and loan association' means any financial 2-21 institution, other than a credit union, chartered under 2-22 the laws of this state or under the laws of the United 2-23 States and domiciled in this state which is authorized 2-24 to receive deposits in this state and which has a mutual 2-25 corporate form. 2-26 48-6-21. (Index) 2-27 Intangible personal property, for the purposes of ad 2-28 valorem taxation, is classified as follows: 2-29 (1) Money; 2-30 (2) Collateral security loans; 2-31 (3) Stocks; 2-32 (4) Accounts receivable and notes not representing 2-33 credits secured by real estate; 2-34 (5) Bonds and debentures of all corporations; 2-35 (6) Long-term notes secured by real estate; 2-36 (7) Short-term notes secured by real estate; 2-37 (8) Restricted foreign intangibles; -2- (Index) LC 18 6388 3- 1 (9) Patents, copyrights, franchises, and all other 3- 2 classes and kinds of intangible personal property not 3- 3 otherwise enumerated; or 3- 4 (10) Computer software as defined in Code Section 3- 5 48-1-8. 3- 6 48-6-22. (Index) 3- 7 The tax imposed by this article shall not apply to: 3- 8 (1) Obligations or evidences of debt of the United 3- 9 States or of this state or its political subdivisions or 3-10 public institutions. Such obligations and evidences of 3-11 debt shall include obligations of the United States 3-12 government agencies and corporations established by acts 3-13 of the Congress of the United States as well as 3-14 industrial development revenue bonds issued pursuant to 3-15 the laws of this state; 3-16 (2) Intangible personal property owned by a trust 3-17 forming part of a pension, profit-sharing, or stock 3-18 bonus plan exempt from federal income taxes under 3-19 Section 401 of the Internal Revenue Code; 3-20 (3) Intangible personal property owned by or irrevocably 3-21 held in trust for the exclusive benefit of a religious, 3-22 educational, or charitable institution, no part of the 3-23 net profit from the operation of which inures to the 3-24 benefit of any private person; 3-25 (4) Intangible personal property owned by a person 3-26 domiciled in this state which has acquired a taxable 3-27 situs and is subjected to tax in another state incident 3-28 to the conduct of business located in the other state, 3-29 except that this paragraph shall not apply to restricted 3-30 foreign intangibles; 3-31 (5) Common voting stock of a subsidiary corporation not 3-32 doing business in this state if at least 90 percent of 3-33 the common voting stock is owned by a domestic 3-34 corporation with its principal place of business in this 3-35 state and was acquired or is held for the purpose of 3-36 enabling the parent company to carry on some part of its 3-37 established line of business through the subsidiary; 3-38 (6) Stock of a corporation organized under the laws of 3-39 this state if the corporation pays all taxes in this 3-40 state as provided by law. For purposes of this -3- (Index) LC 18 6388 4- 1 paragraph, the term 'corporation' also means any 4- 2 depository financial institution; 4- 3 (7) Stock of a domesticated foreign corporation if the 4- 4 corporation pays to this state or its political 4- 5 subdivisions all taxes as provided by law; 4- 6 (8) Assets representing mandatory reserve requirements 4- 7 imposed, by statute or otherwise, on depository 4- 8 financial institutions subject to the tax on intangible 4- 9 property; 4-10 (9) Stock of the Federal Reserve Bank, the Government 4-11 National Mortgage Association, the Federal National 4-12 Mortgage Association, and other corporations and 4-13 associations established by acts of the Congress of the 4-14 United States; 4-15 (10) Mandatory deposits with the Federal Reserve Bank or 4-16 others required by statute or regulations; 4-17 (11) Federal or correspondent funds sold and securities 4-18 and other intangible assets purchased under agreements 4-19 to resell to the extent they are offset by federal or 4-20 correspondent funds purchased and securities and other 4-21 intangible assets sold under agreements to repurchase; 4-22 (12) Customer's liabilities to depository financial 4-23 institutions on acceptances outstanding to the extent 4-24 they are offset by liabilities of depository financial 4-25 institutions on acceptances executed and outstanding; 4-26 (13) Receivables arising from the lease of tangible 4-27 personal property, provided that tangible property tax 4-28 is due upon such property; 4-29 (14) Intercompany loans or advances from a parent 4-30 corporation to a subsidiary, or vice versa, or from one 4-31 subsidiary to another subsidiary, provided that the 4-32 parent corporation owns, either directly or through 4-33 other subsidiaries, more than 90 percent of the common 4-34 voting stock of any subsidiary which is a party to any 4-35 such transaction; 4-36 (15) Intangible personal property owned by an 4-37 international banking agency or domestic international 4-38 banking facility licensed to do business in this state; 4-39 and 4-40 (16) Stock held in a foreign corporation which was a 4-41 party to a reorganization prior to January 1, 1992, -4- (Index) LC 18 6388 5- 1 under the provisions of Part 19 of Article 2 of Chapter 5- 2 1 of Title 7 if the stock of another corporation which 5- 3 was a party to such reorganization and which was 5- 4 acquired in such reorganization was exempt from such tax 5- 5 prior to such reorganization. 5- 6 48-6-23. (Index) 5- 7 (a) A property tax is levied annually as of January 1 of 5- 8 each year at the following rates: 5- 9 (1) Ten cents upon each $1,000.00 of the fair market 5-10 value of all personal property classified for taxation 5-11 as intangible personal property in Code Section 48-6-21, 5-12 including all restricted foreign intangibles. The tax 5-13 is not levied by this paragraph on intangible personal 5-14 property classified as collateral security loans, 5-15 long-term notes secured by real estate, or stocks, 5-16 bonds, and debentures; except for restricted foreign 5-17 intangibles which are taxed in this paragraph and not 5-18 otherwise; 5-19 (2) Twenty-five cents upon each $1,000.00 of the fair 5-20 market value of all collateral security loans; 5-21 (3) One dollar upon each $1,000.00 of the fair market 5-22 value of all stocks in all corporations except those 5-23 specifically exempted by law; and 5-24 (4) One dollar upon each $1,000.00 of the fair market 5-25 value of all bonds and debentures of all corporations. 5-26 The tax rate upon notes of corporations, other than 5-27 long-term notes secured by real estate, shall be the 5-28 rate specified in paragraph (1) of subsection (a) of 5-29 this Code section, regardless of the maturity date of 5-30 any such note or notes. 5-31 (b) Long-term notes secured by real estate, as defined in 5-32 Article 3 of this chapter, shall be recorded and taxed as 5-33 provided in Article 3 of this chapter. 5-34 48-6-24. (Index) 5-35 (a) The taxes imposed by Code Section 48-6-23 shall be in 5-36 lieu of all other state, county, municipal, and district 5-37 property taxes on intangible personal property classified 5-38 for taxation as specified in this article. All intangible 5-39 personal property not otherwise exempted shall be taxed 5-40 without deduction of any indebtedness or liability of the 5-41 taxpayer. -5- (Index) LC 18 6388 6- 1 (b) A sale or transfer of accounts receivable or of notes 6- 2 not representing credits secured by real estate to a 6- 3 nonresident of this state shall be void as far as tax 6- 4 liability is concerned. Sales or transfers to nonresidents 6- 5 of accounts receivable or notes retaining any interest 6- 6 whatever by the seller shall be void with respect to tax 6- 7 liability. The physical removal of such accounts 6- 8 receivable and notes from the state by any person doing 6- 9 business in the state shall not avoid liability for the 6-10 tax imposed by this article. 6-11 48-6-25. (Index) 6-12 Every resident and nonresident person is subject to the 6-13 tax imposed by this article on as much of his property 6-14 taxable under this article as has been acquired in the 6-15 conduct of, or has been used incident to, business carried 6-16 on or property located in this state. Each such person 6-17 shall report the property and pay taxes on the property as 6-18 provided in this article. Stock of a foreign subsidiary 6-19 corporation held by a foreign parent corporation whose 6-20 corporate headquarters are located in this state will not 6-21 be deemed to have been acquired in the conduct of, or used 6-22 incident to, business carried on or property located in 6-23 this state, and the stock of such foreign subsidiary 6-24 corporation will not otherwise be deemed to have a taxable 6-25 situs in this state. 6-26 48-6-26. (Index) 6-27 The taxable situs of all intangible trust property, if the 6-28 trust was or is created by a resident of this state, is 6-29 fixed and declared, if the settlor or maker is living, to 6-30 be the county of this state of which the settlor or maker 6-31 of the trust is a resident or, if the settlor or maker is 6-32 deceased, the county of this state of which the settlor or 6-33 maker of the trust was a resident at the time of his 6-34 death. 6-35 48-6-26.1. (Index) 6-36 Notwithstanding any other provision of law to the 6-37 contrary, the commissioner shall grant, upon written 6-38 request, an extension of four months for filing returns, 6-39 declarations, or other documents required under this 6-40 article whenever, in the reasonable exercise of his 6-41 judgment, a good cause for the extension exists. The 6-42 commissioner shall keep a record of every extension 6-43 granted and the reason for the extension. No such -6- (Index) LC 18 6388 7- 1 extension shall operate to delay the payment of a tax 7- 2 unless a bond satisfactory to the commissioner is posted. 7- 3 The commissioner shall by rule and regulation provide for 7- 4 the administration of this Code section. 7- 5 48-6-27. (Index) 7- 6 (a) Every person owning intangible personal property 7- 7 classified for taxation under this article shall file a 7- 8 return of such property. The return shall: 7- 9 (1) Describe in detail each item of property (including 7-10 exempt as well as taxable property, except obligations 7-11 of the United States); 7-12 (2) Give a description of the property in the form 7-13 required by the commissioner; 7-14 (3) Show the face value of each item of intangible 7-15 personal property; 7-16 (4) Show such other information pertaining to the return 7-17 as reasonably required by the commissioner; and 7-18 (5) Be filed with the commissioner on or before April 15 7-19 of each year. 7-20 (b) The return shall be separately sworn to and shall be 7-21 filed by every owner of the intangible personal property 7-22 taxable under this article. 7-23 (c) This Code section shall not apply to intangible 7-24 personal property belonging to: 7-25 (1) The United States; 7-26 (2) This state or any political subdivision of this 7-27 state; 7-28 (3) A religious, educational, or charitable 7-29 organization; 7-30 (4) A trust exempt from federal income taxes under 7-31 Section 401 of the Internal Revenue Code; or 7-32 (5) A nonprofit cooperative association. 7-33 (d) Money belonging to a person residing outside this 7-34 state (except as provided in Code Section 48-6-25) shall 7-35 be neither returnable nor taxable. 7-36 (e)(1) It is the intent of this subsection to carry into 7-37 effect the constitutional authorization to exempt from 7-38 the return and payment requirements of this article -7- (Index) LC 18 6388 8- 1 those returns on which the tax due exceeds the 8- 2 reasonable cost of administering the tax. 8- 3 (2) No return need be filed pursuant to this Code 8- 4 section nor tax paid as required by this article if the 8- 5 amount of tax due on all intangible property owned in 8- 6 whole or in part by the person liable for the tax is 8- 7 less than $20.00. 8- 8 48-6-28. (Index) 8- 9 Any person including, but not limited to, an agent holding 8-10 money belonging to others may make returns for the other 8-11 persons and may pay the tax on the money as provided in 8-12 this article when so authorized by the person owning the 8-13 money. 8-14 48-6-29. (Index) 8-15 (a) Any bank or trust company organized under the laws of 8-16 this state or of the United States and having on deposit 8-17 money subject to taxation under this article may make a 8-18 return to the commissioner of the aggregate amount of 8-19 money on deposit with the bank owned by a taxpayer and may 8-20 pay the tax on the money on the taxpayer's behalf when so 8-21 authorized by the taxpayer. A return by a bank or trust 8-22 company shall state the aggregate amount of money it has 8-23 on deposit which is subject to taxation under this article 8-24 and which is owned by the taxpayer authorizing the bank to 8-25 make the return. The return shall state also the amount 8-26 of money having a taxable situs in each county, 8-27 municipality, or special tax district in which any of the 8-28 money has a taxable situs. 8-29 (b) If a bank or trust company elects to make a return and 8-30 pay the tax, any person having money on deposit on which 8-31 the bank has made a return and paid the taxes shall be 8-32 deemed to have made a return of his money for taxation if 8-33 he states in his return the name of the bank or trust 8-34 company authorized to make a return of his money for 8-35 taxation and to pay the tax on the money. 8-36 (c) The amount of tax paid by any bank for a taxpayer 8-37 shall be charged to the account of the taxpayer. 8-38 48-6-30. (Index) 8-39 In addition to all other penalties and interest provided 8-40 by law, every taxpayer failing to return for taxation all 8-41 intangible personal property which it is his duty to -8- (Index) LC 18 6388 9- 1 return as required by this article shall pay a penalty, as 9- 2 part of the tax imposed by this article, in an amount 9- 3 equal to 25 percent of the original tax on property not 9- 4 returned. 9- 5 48-6-31. (Index) 9- 6 Every foreign corporation doing business or owning 9- 7 property in this state and each domestic corporation, when 9- 8 the stocks and bonds of the foreign or domestic 9- 9 corporation are subject to tax under this article, shall 9-10 make on or before March 1 of each year a true, correct, 9-11 and verified report to the commissioner. The report shall 9-12 give in the form required by the commissioner the names 9-13 and addresses of persons in this state who held its shares 9-14 of stock or its registered bonds on the immediately 9-15 preceding January 1 and, in addition, a list of stock (or, 9-16 in the case of a domestic corporation, preferred stock) or 9-17 registered bonds transferred from such persons between 9-18 November 1 and January 1 immediately preceding the date of 9-19 the return. 9-20 48-6-32. (Index) 9-21 Willful failure to return any property to the commissioner 9-22 for taxation as required by this article shall be a bar to 9-23 any action upon the property in any court and may be 9-24 pleaded as a complete defense to the action, but the 9-25 holder of the property may at any time pay all taxes, 9-26 accrued interest, and penalties. Payment in full shall 9-27 relieve the holder from the penalty provided in this Code 9-28 section. 9-29 48-6-33. (Index) 9-30 Intangible personal property transferred prior to January 9-31 1 to avoid the tax imposed by this article or to secure a 9-32 reduction in the rate of the tax imposed by this article 9-33 is subject to the tax imposed by this article. 9-34 48-6-34. (Index) 9-35 As soon as practicable after receipt of the returns of 9-36 intangible personal property as required by this article, 9-37 the commissioner shall examine each return and fix the 9-38 value of that property contained in the return which can 9-39 be centrally assessed. 9-40 48-6-35. (Index) -9- (Index) LC 18 6388 10- 1 (a) The commissioner shall certify the assessments fixed 10- 2 pursuant to Code Section 48-6-34 to the various tax 10- 3 commissioners or tax receivers according to the situs of 10- 4 the property, such certification to be made with respect 10- 5 to all property listed on returns where the property is 10- 6 assessed for at least $5.00 or where the commissioner 10- 7 determines that the final assessment on all property owned 10- 8 in whole or in part by the taxpayer would be for at least 10- 9 $5.00. Each tax commissioner or tax receiver shall record 10-10 the value certified by the commissioner, shall assess all 10-11 property certified but not assessed, and shall cause the 10-12 aggregate assessments so fixed to be entered on a separate 10-13 intangible personal property tax digest of the county. 10-14 (b) At or before the time certification is made to local 10-15 officials, the commissioner shall notify the taxpayer of 10-16 the assessment. The taxpayer shall have 15 days within 10-17 which he may offer objections. 10-18 (c) The commissioner, in the event of an error, may make a 10-19 corrected certification. In no event shall such a 10-20 correction be made after the tax has become delinquent 10-21 under this article. 10-22 48-6-36. (Index) 10-23 Notwithstanding the fact that the assessment of all 10-24 intangible personal property is fixed by the commissioner, 10-25 the tax receiver or tax commissioner shall be entitled for 10-26 his services to his usual commissions as though he himself 10-27 made the assessment. 10-28 48-6-37. (Index) 10-29 The taxes on property imposed by this article at the rates 10-30 fixed in this article shall be collected by the tax 10-31 commissioners or tax collectors, subject to the provisions 10-32 of law as to remuneration of the tax commissioner or tax 10-33 collector and subject to all the remedies provided by law 10-34 for enforcement or collection of real and tangible 10-35 personal property taxes. 10-36 48-6-38. (Index) 10-37 In all applications to restrain or enjoin the collection 10-38 of any tax imposed by this article, the judge, should he 10-39 grant a restraining order or temporary injunction, shall 10-40 require the petitioner to give a good and sufficient bond 10-41 payable to the tax commissioner or tax collector in double 10-42 the amount of the tax the collection of which is sought to -10- (Index) LC 18 6388 11- 1 be enjoined. The bond shall be approved by the clerk of 11- 2 superior court and shall be conditioned to pay the tax in 11- 3 the event the petitioner does not finally prevail in his 11- 4 effort to resist the payment of the tax. If the petitioner 11- 5 does not finally prevail, the tax commissioner or tax 11- 6 collector shall bring an action on the bond and shall 11- 7 distribute the amount recovered pursuant to Code Sections 11- 8 48-6-39, 48-6-40, and 48-6-41. 11- 9 48-6-39. (Index) 11-10 The tax commissioner or tax collector, on the basis of his 11-11 records and of certificates which shall be supplied by 11-12 each school district, municipality, and other tax district 11-13 in the county, shall distribute at least monthly the 11-14 revenue collected from each owner of intangible personal 11-15 property between the state and the various local tax 11-16 districts in the manner provided in this article. Each 11-17 year the millage rates used in the distributions of 11-18 revenue under this Code section shall be based upon the 11-19 immediately preceding year's millage rate of each 11-20 participating tax authority as provided in this article. 11-21 48-6-40. (Index) 11-22 Revenue derived from taxes on intangible personal property 11-23 shall be divided among the state and all other tax 11-24 jurisdictions and districts including, but not limited to, 11-25 county and municipal districts, which levy or cause to be 11-26 levied for their benefit a property tax on real and 11-27 tangible personal property having the same taxable situs 11-28 as the intangible personal property from which the revenue 11-29 is derived. The distribution shall be made according to 11-30 the proportion that the millage rate levied for the state 11-31 and each other tax jurisdiction or district respectively 11-32 bears to the total millage rate levied for all purposes 11-33 applicable to real and tangible personal property having 11-34 the same taxable situs as the intangible personal property 11-35 on which the intangible tax was collected. The revenue 11-36 distributed to municipalities having independent school 11-37 systems supported by taxes levied by the municipality 11-38 shall be divided between the municipality and the 11-39 independent school system according to the proportion that 11-40 the millage rate levied by the municipality for nonschool 11-41 purposes and the millage rate levied for school purposes 11-42 bear to the total millage rate levied by the municipality 11-43 for all purposes. The tax levied by this article shall be 11-44 deemed to be levied by the participating tax authorities -11- (Index) LC 18 6388 12- 1 in the proportion that the millage rate of each 12- 2 participating tax authority bears to the aggregate millage 12- 3 rate of all the participating tax authorities. 12- 4 48-6-41. (Index) 12- 5 In the event any distribution or part of a distribution as 12- 6 provided in this article is adjudged to be invalid for any 12- 7 reason, such distribution or part of a distribution shall 12- 8 be paid into the general fund of the state in the same 12- 9 manner and for the same purposes as provided in this 12-10 article for the state's share of the revenues derived from 12-11 the tax imposed by this article. 12-12 48-6-42. (Index) 12-13 The schedules required by this article to be filed with 12-14 the commissioner shall be subject to hearings and appeals 12-15 in all respects as provided by law for income taxes. 12-16 48-6-43. (Index) 12-17 The intangible personal property tax digest, returns, and 12-18 related records shall be confidential and shall not be 12-19 subject to inspection by any person other than authorized 12-20 personnel of appropriate tax administrators. Nothing in 12-21 this Code section, however, shall prevent any disclosure 12-22 necessary or proper to the collection of any tax in any 12-23 administrative or court proceeding. 12-24 48-6-44. (Index) 12-25 (a) It shall be unlawful for any person willfully to 12-26 violate any provision of this article or willfully to fail 12-27 to do any act required of him by this article. 12-28 (b) Any person who violates subsection (a) of this Code 12-29 section shall be guilty of a misdemeanor.", 12-30 and inserting in its place the following: "ARTICLE 2 RESERVED". SECTION 2. 12-31 This Act shall become effective on December 31, 1995. SECTION 3. 12-32 All laws and parts of laws in conflict with this Act are 12-33 repealed. -12- (Index)

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