HB-5408, As Passed House, November 8, 2007

 

 

 

 

 

 

 

 

 

 

 

 

 

SUBSTITUTE FOR

 

HOUSE BILL NO. 5408

 

 

 

 

 

 

 

 

 

 

 

 

     A bill to amend 2007 PA 36, entitled

 

"Michigan business tax act,"

 

by amending the title and sections 265, 403, 447, 515, and 601 (MCL

 

208.1265, 208.1403, 208.1447, 208.1515, and 208.1601) and by adding

 

chapter 2C; and to repeal acts and parts of acts.

 

THE PEOPLE OF THE STATE OF MICHIGAN ENACT:

 

TITLE

 

     An act to provide meet deficiencies in state funds by

 

providing for the imposition, levy, computation, collection,

 

assessment, reporting, payment, and enforcement of taxes on certain

 

commercial, business, and financial activities; to prescribe the

 

powers and duties of public officers and state departments; to

 

provide for the inspection of certain taxpayer records; to provide


 

for interest and penalties; to provide exemptions, credits, and

 

refunds; to provide for the disposition of funds; to provide for

 

the interrelation of this act with other acts; and to make

 

appropriations.

 

     Sec. 265. (1) For a financial institution, tax base means the

 

financial institution's net capital. Net capital means equity

 

capital as computed in accordance with generally accepted

 

accounting principles less goodwill arising from purchase

 

accounting adjustments for transactions that occurred after July 1,

 

2007, and the book value of United States obligations and Michigan

 

obligations. If the financial institution does not maintain its

 

books and records in accordance with generally accepted accounting

 

principles, net capital shall be computed in accordance with the

 

books and records used by the financial institution, so long as the

 

method fairly reflects the financial institution's net capital for

 

purposes of the tax levied by this chapter. Net capital does not

 

include up to 125% of the minimum regulatory capitalization

 

requirements of a person subject to the tax imposed under chapter

 

2A.

 

     (2) Net capital shall be determined by adding the financial

 

institution's net capital as of the close of the current tax year

 

and preceding 4 tax years and dividing the resulting sum by 5. If a

 

financial institution has not been in existence for a period of 5

 

tax years, net capital shall be determined by adding together the

 

financial institution's net capital for the number of tax years the

 

financial institution has been in existence and dividing the

 

resulting sum by the number of years the financial institution has


 

been in existence. For purposes of this section, a partial year

 

shall be treated as a full year.

 

     (3) For purposes of this section, each of the following

 

applies:

 

     (a) A change in identity, form, or place of organization of 1

 

financial institution shall be treated as if a single financial

 

institution had been in existence for the entire tax year in which

 

the change occurred and each tax year after the change.

 

     (b) The combination of 2 or more financial institutions into 1

 

shall be treated as if the constituent financial institutions had

 

been a single financial institution in existence for the entire tax

 

year in which the combination occurred and each tax year after the

 

combination, and the book values and deductions for United States

 

obligations and Michigan obligations of the constituent

 

institutions shall be combined. A combination shall include any

 

acquisition required to be accounted for by the surviving financial

 

institution in accordance with generally accepted accounting

 

principles or a statutory merger or consolidation.

 

CHAPTER 2C

 

     Sec. 281. (1) In addition to the taxes imposed and levied

 

under this act and subject to the limitations provided under

 

subsections (2) and (3), to meet deficiencies in state funds an

 

annual surcharge is imposed and levied on each taxpayer equal to

 

the following percentage of the taxpayer's tax liability under this

 

act after allocation or apportionment to this state under this act

 

but before calculation of the various credits available under this

 

act:


 

     (a) For each taxpayer other than a person subject to the tax

 

imposed and levied under chapter 2B:

 

     (i) For tax years ending after December 31, 2007 and before

 

January 1, 2009, 32.9%.

 

     (ii) For tax years ending after December 31, 2008, 27.3%.

 

     (b) For a person subject to the tax imposed and levied under

 

chapter 2B:

 

     (i) For tax years ending after December 31, 2007 and before

 

January 1, 2009, 27.7%.

 

     (ii) For tax years ending after December 31, 2008, 23.4%.

 

     (2) The amount of the surcharge imposed and levied on any

 

taxpayer under subsection (1)(a) shall not exceed $2,000,000.00 for

 

any single tax year.

 

     (3) The surcharge imposed and levied under this section does

 

not apply to a person subject to the tax imposed and levied under

 

chapter 2A.

 

     (4) The surcharge imposed and levied under this section shall

 

constitute a part of the tax imposed under this act and shall be

 

administered, collected, and enforced as provided under this act.

 

     Sec. 403. (1) Notwithstanding any other provision in this act,

 

the credits provided in this section shall be taken before any

 

other credit under this act. The total combined credit allowed

 

under this section shall not exceed 65% of the total tax liability

 

imposed under this act.

 

     (2) Subject to the limitation in subsection (1), a taxpayer

 

may claim a credit against the tax imposed by this act equal to

 

0.370% of the taxpayer's compensation in this state. For purposes


 

of this subsection, a taxpayer includes a person subject to the tax

 

imposed under chapter 2B and a person described in section 239(2)

 

and subject to the tax imposed under chapter 2A. A professional

 

employer organization shall not include payments by the

 

professional employer organization to the officers and employees of

 

a client of the professional employer organization whose employment

 

operations are managed by the professional employer organization. A

 

client may include payments by the professional employer

 

organization to the officers and employees of the client whose

 

employment operations are managed by the professional employer

 

organization.

 

     (3) Subject to the limitation in subsection (1), a taxpayer

 

may claim a credit against the tax imposed by this act equal to

 

2.9% multiplied by the result of subtracting the sum of the amounts

 

calculated under subdivisions (d), (e), and (f) from the sum of the

 

amounts calculated under subdivisions (a), (b), and (c):

 

     (a) Calculate the cost, including fabrication and

 

installation, paid or accrued in the taxable year of tangible

 

assets of a type that are, or under the internal revenue code will

 

become, eligible for depreciation, amortization, or accelerated

 

capital cost recovery for federal income tax purposes, provided

 

that the assets are physically located in this state for use in a

 

business activity in this state and are not mobile tangible assets.

 

     (b) Calculate the cost, including fabrication and

 

installation, paid or accrued in the taxable year of mobile

 

tangible assets of a type that are, or under the internal revenue

 

code will become, eligible for depreciation, amortization, or


 

accelerated capital cost recovery for federal income tax purposes.

 

This amount shall be multiplied by the apportionment factor for the

 

tax year as prescribed in chapter 3.

 

     (c) For tangible assets, other than mobile tangible assets,

 

purchased or acquired for use outside of this state in a tax year

 

beginning after December 31, 2007 and subsequently transferred into

 

this state and purchased or acquired for use in a business

 

activity, calculate the federal basis used for determining gain or

 

loss as of the date the tangible assets were physically located in

 

this state for use in a business activity plus the cost of

 

fabrication and installation of the tangible assets in this state.

 

     (d) If the cost of tangible assets described in subdivision

 

(a) was paid or accrued in a tax year beginning after December 31,

 

2007, or before December 31, 2007 to the extent the credit is used

 

and at the rate at which the credit was used under former 1975 PA

 

228 or this act, calculate the gross proceeds or benefit derived

 

from the sale or other disposition of the tangible assets minus the

 

gain, multiplied by the apportionment factor for the taxable year

 

as prescribed in chapter 3, and plus the loss, multiplied by the

 

apportionment factor for the taxable year as prescribed in chapter

 

3 from the sale or other disposition reflected in federal taxable

 

income and minus the gain from the sale or other disposition added

 

to the business income tax base in section 201.

 

     (e) If the cost of tangible assets described in subdivision

 

(b) was paid or accrued in a tax year beginning after December 31,

 

2007, or before December 31, 2007 to the extent the credit is used

 

and at the rate at which the credit was used under former 1975 PA


 

228 or this act, calculate the gross proceeds or benefit derived

 

from the sale or other disposition of the tangible assets minus the

 

gain and plus the loss from the sale or other disposition reflected

 

in federal taxable income and minus the gain from the sale or other

 

disposition added to the business income tax base in section 201.

 

This amount shall be multiplied by the apportionment factor for the

 

tax year as prescribed in chapter 3.

 

     (f) For assets purchased or acquired in a tax year beginning

 

after December 31, 2007, or before December 31, 2007 to the extent

 

the credit is used and at the rate at which the credit was used

 

under former 1975 PA 228 or this act, that were eligible for a

 

credit under subdivision (a) or (c) and that were transferred out

 

of this state, calculate the federal basis used for determining

 

gain or loss as of the date of the transfer.

 

     (4) For a tax year in which the amount of the credit

 

calculated under subsection (3) is negative, the absolute value of

 

that amount is added to the taxpayer's tax liability for the tax

 

year.

 

     (5) A taxpayer that claims a credit under this section is not

 

prohibited from claiming a credit under section 405. However, the

 

taxpayer shall not claim a credit under this section and section

 

405 based on the same costs and expenses.

 

     Sec. 447. (1) An eligible taxpayer may claim a credit against

 

the tax imposed by this act equal to 0.535% 1.0% of the taxpayer's

 

compensation in this state. , not to exceed $4,500,000.00. If the

 

limitation on the amount of the surcharge that may be levied and

 

imposed upon an eligible taxpayer under section 281(1)(a) is


 

$2,000,000.00 or less, then the amount of the credit allowed under

 

this section shall not exceed $4,500,000.00.

 

     (2) If the amount of the credit allowed under this section

 

exceeds the tax liability of the taxpayer for the tax year, that

 

excess shall not be refunded and shall not be carried forward as an

 

offset to the tax liability in subsequent tax years.

 

     (3) A taxpayer that claims a credit under this section shall

 

not claim a credit under section 449.

 

     (4) As used in this section, "eligible taxpayer" means a

 

taxpayer that meets all of the following conditions:

 

     (a) Operates at least 17,000,000 square feet of enclosed

 

retail space and 2,000,000 square feet of enclosed warehouse space

 

in this state.

 

     (b) Sells all of the following at retail:

 

     (i) Fresh, frozen, or processed food, food products, or

 

consumable necessities:

 

     (ii) Prescriptions and over-the-counter medications.

 

     (iii) Health and beauty care products.

 

     (iv) Cosmetics.

 

     (v) Pet products.

 

     (vi) Carbonated beverages.

 

     (vii) Beer, wine, or liquor.

 

     (c) Sales of the items listed in subdivision (b) represent

 

more than 35% of the taxpayer's total sales in the tax year.

 

     (d) Maintains its headquarters operation in this state.

 

     Sec. 515. (1) In fiscal year 2007-2008, $136,000,000.00

 

$341,000,000.00 of the revenue collected under this act shall be


 

distributed to the school aid fund and the balance shall be

 

deposited into the general fund. In fiscal year 2008-2009,

 

$479,000,000.00 $729,000,000.00 of the revenue collected under this

 

act shall be distributed to the school aid fund and the balance

 

shall be deposited into the general fund. For each fiscal year

 

after the 2008-2009 fiscal year, that amount from the immediately

 

preceding fiscal year as adjusted by an amount equal to the growth

 

in the United States consumer price index in the immediately

 

preceding year shall be distributed to the school aid fund and the

 

balance shall be deposited into the general fund.

 

     (2) As used in this section, "United States consumer price

 

index" means the United States consumer price index for all urban

 

consumers as defined and reported by the United States department

 

of labor, bureau of labor statistics.

 

     Sec. 601. (1) For the 2008 fiscal year, except as otherwise

 

provided under subsection (4) (5), if total net cash payments from

 

the tax imposed and levied under this act plus any net cash

 

payments from former 1975 PA 228 less any net cash payments made by

 

insurance companies under either act this act or former 1975 PA 228

 

exceed $2,398,000,000.00, 50% of that $2,796,000,000.00, the excess

 

shall be refunded in the immediately succeeding fiscal year as

 

provided in subsection (6). (5) and the remaining 50% shall be

 

deposited into the countercyclical budget and economic

 

stabilization fund pursuant to section 353 of the management and

 

budget act, 1984 PA 431, MCL 18.1353.

 

     (2) For the 2009 fiscal year, except as otherwise provided

 

under subsection (4) (5), if total net cash payments from the tax


 

imposed and levied under this act, excluding any revenue collected

 

pursuant to chapter 2A, exceed the fiscal year 2009 base, 50% of

 

that the excess shall be refunded in the immediately succeeding

 

fiscal year as provided in subsection (6). (5) and the remaining

 

50% shall be deposited into the countercyclical budget and economic

 

stabilization fund pursuant to section 353 of the management and

 

budget act, 1984 PA 431, MCL 18.1353. To calculate the fiscal year

 

2009 base, the department shall multiply $2,398,000,000.00

 

$3,238,000,000.00 by 1.01 and then multiply this product by 2009

 

fiscal year Michigan personal income divided by 2008 fiscal year

 

Michigan personal income.

 

     (3) For the 2010 fiscal year, except as otherwise provided

 

under subsection (4) (5), if total net cash payments from the tax

 

imposed and levied under this act, excluding any revenue collected

 

pursuant to chapter 2A, exceed the fiscal year 2010 base, 50% of

 

that the excess shall be refunded in the immediately succeeding

 

fiscal year as provided in subsection (6). (5) and the remaining

 

50% shall be deposited into the countercyclical budget and economic

 

stabilization fund pursuant to section 353 of the management and

 

budget act, 1984 PA 431, MCL 18.1353. To calculate the fiscal year

 

2010 base, the department shall multiply $2,398,000,000.00

 

$3,180,000,000.00 by 1.0201 and then multiply this product by 2010

 

fiscal year Michigan personal income divided by 2008 fiscal year

 

Michigan personal income.

 

     (4) For each fiscal year after fiscal year 2010, except as

 

otherwise provided in subsection (5), if total net cash payments

 

from the tax imposed and levied under this act, excluding any


 

revenue collected pursuant to chapter 2A, exceed the fiscal year

 

base, the excess shall be refunded in the immediately succeeding

 

fiscal year as provided in subsection (6). To calculate the fiscal

 

year base, the department shall multiply the fiscal year base for

 

the immediately preceding fiscal year by 1.01 and then by a

 

fraction the numerator of which is fiscal year personal income for

 

the fiscal year for which the calculation is being performed and

 

the denominator of which is fiscal year personal income for the

 

fiscal year preceding the fiscal year for which the calculation is

 

being performed.

 

     (5) (4) If the amount of the total net cash payments collected

 

from the tax imposed and levied under this act, excluding any

 

revenue collected pursuant to chapter 2A, exceeds the amount

 

described in the applicable subsection by less than $5,000,000.00,

 

then all of that excess shall be deposited into the countercyclical

 

budget and economic stabilization fund pursuant to section 353

 

created under section 351 of the management and budget act, 1984 PA

 

431, MCL 18.1353 MCL 18.1351.

 

     (6) (5) The For the 2008 fiscal year, the refund available

 

authorized under subsection (1), (2), or (3), or (4) shall be

 

applied pro rata to the taxpayers that made positive net cash

 

payments during the fiscal year. The taxpayer's pro rata share

 

shall be the total amount to be refunded under subsection (1), (2),

 

or (3), or (4) multiplied by a fraction the numerator of which is

 

the positive net payments made by the taxpayer during the fiscal

 

year and the denominator of which is the sum of the positive net

 

cash payments made by all taxpayers during the fiscal year. For


 

each fiscal year after the 2008 fiscal year, the refund authorized

 

under subsection (1), (2), (3), or (4) shall be applied pro rata to

 

the taxpayers that had a surcharge liability imposed and levied

 

under section 281 during the immediately preceding fiscal year. The

 

taxpayer's pro rata share shall be the total amount to be refunded

 

under subsection (1), (2), (3), or (4) multiplied by a fraction the

 

numerator of which is the surcharge liability imposed and levied on

 

the taxpayer under section 281 during the immediately preceding

 

fiscal year and the denominator of which is the sum of all

 

surcharge liabilities imposed on all taxpayers under section 281

 

during the immediately preceding fiscal year.

 

     (7) (6) As used in this section:

 

     (a) "Fiscal year" means the state fiscal year that commences

 

October 1 and continues through September 30.

 

     (b) "Fiscal year Michigan personal income" is means the

 

average of the 4 quarterly values for the fiscal year, as published

 

by the United States department of commerce bureau of economic

 

analysis. Fiscal year personal income for subsection (2) is

 

calculated using the personal income totals published in December

 

2009. Fiscal year personal income for subsection (3) is calculated

 

using the personal income totals published in December 2010. the

 

December immediately following the end of the fiscal year.

 

     (c) "Net cash payments" for the fiscal year are equal to cash

 

annual and estimated payments made during the fiscal year less

 

refunds paid during the fiscal year. Refunds paid under this

 

section are not used to reduce net cash payments for purposes of

 

calculating refunds paid out under this section.


 

     Enacting section 1. (1) Sections 353c, 353e, and 353f of the

 

management and budget act, 1984 PA 431, MCL 18.1353c, 18.1353e, and

 

18.1353f, are repealed.

 

     (2) Section 3d of the use tax act, 1937 PA 94, MCL 205.93d, is

 

repealed immediately after it takes effect on December 1, 2007.

 

     Enacting section 2. Section 281 of the Michigan business tax

 

act, 2007 PA 36, MCL 208.1281, as added by this amendatory act, and

 

sections 265, 403, 447, 515, and 601 of the Michigan business tax

 

act, 2007 PA 36, MCL 208.1265, 208.1403, 208.1447, 208.1515, and

 

208.1601, as amended by this amendatory act, take effect January 1,

 

2008 and apply to all business activity occurring after December

 

31, 2007.