Senate Bill 1698c1

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    Florida Senate - 1998                           CS for SB 1698

    By the Committee on Ways and Means; and Senator Ostalkiewicz





    301-2067A-98

  1                      A bill to be entitled

  2         An act relating to financial matters (RAB);

  3         amending s. 72.011, F.S.; providing for

  4         adoption of procedures for notifying a taxpayer

  5         of an assessment or denial of a refund;

  6         amending s. 199.052, F.S.; prescribing

  7         conditions under which a trust will be

  8         considered a Florida-situs trust; amending s.

  9         213.21, F.S.; providing for conferences

10         relating to denial of refunds; providing for

11         closing agreements; amending s. 220.222, F.S.;

12         prescribing conditions under which a taxpayer

13         will be considered not in compliance with s.

14         220.32, F.S., for purposes of granting

15         extensions; amending s. 624.515, F.S.;

16         providing for determination of the percentage

17         of fire insurance within an insurance line;

18         amending s. 896.102, F.S.; authorizing the

19         Department of Revenue to adopt rules for

20         reporting certain business transactions;

21         providing an effective date.

22

23  Be It Enacted by the Legislature of the State of Florida:

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25         Section 1.  Paragraph (b) of subsection (2) of section

26  72.011, Florida Statutes, is amended to read:

27         72.011  Jurisdiction of circuit courts in specific tax

28  matters; administrative hearings and appeals; time for

29  commencing action; parties; deposits.--

30         (2)

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    Florida Senate - 1998                           CS for SB 1698
    301-2067A-98




  1         (b)  The date on which an assessment or a denial of

  2  refund becomes final and procedures a procedure by which a

  3  taxpayer must be notified of the assessment or of the denial

  4  of refund must be established:

  5         1.  By rule adopted by the Department of Revenue;

  6         2.  With respect to assessments or refund denials under

  7  chapter 207, by rule adopted by the Department of Highway

  8  Safety and Motor Vehicles;

  9         3.  With respect to assessments or refund denials under

10  chapters 210, 550, 561, 562, 563, 564, and 565, by rule

11  adopted by the Department of Business and Professional

12  Regulation; or

13         4.  With respect to taxes that a county collects or

14  enforces under s. 125.0104(10) or s. 212.0305(5), by an

15  ordinance that may additionally provide for informal dispute

16  resolution procedures in accordance with s. 213.21.

17         Section 2.  Subsection (5) of section 199.052, Florida

18  Statutes, is amended to read:

19         199.052  Annual tax returns; payment of annual tax.--

20         (5)  The trustee of a Florida-situs trust is primarily

21  responsible for returning the trust's intangible personal

22  property and paying the annual tax on it.

23         (a)  A trust has a Florida situs when:

24         1.  All trustees are residents of the state;

25         2.  There are three or more trustees sharing equally in

26  the ownership, management, or control of the trust's

27  intangible property, and the majority of the trustees are

28  residents of this state; or

29         3.  Trustees consist of both residents and nonresidents

30  and management or control of the trust is with a resident

31  trustee.

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    Florida Senate - 1998                           CS for SB 1698
    301-2067A-98




  1         (b)  When trustees consist of both residents and

  2  nonresidents and management or control is with a nonresident

  3  trustee, the trust does not have Florida situs and no return

  4  is necessary by any resident trustee.

  5         (c)  A portion of the trust has Florida situs when

  6  there are two trustees, one a resident of this state and one a

  7  nonresident, and they share equally in the ownership,

  8  management, or control of the trust's intangible property. The

  9  tax on such property shall be based on the value apportioned

10  between them.

11         (d)  If there is more than one trustee in the state,

12  only one tax return for the trust must be filed.

13         (e)  Nothing in this subsection shall be construed so

14  as to levy the annual tax on trust assets where the settlor is

15  not a Florida resident.

16         (f)  The trust's beneficiaries, however, may

17  individually return their equitable shares of the trust's

18  intangible personal property and pay the tax on such shares,

19  in which case the trustee need not return such property or pay

20  such tax, although the department may require the trustee to

21  file an informational return.

22         Section 3.  Paragraph (a) of subsection (1) and

23  paragraph (a) of subsection (2) of section 213.21, Florida

24  Statutes, are amended to read:

25         213.21  Informal conferences; compromises.--

26         (1)(a)  The Department of Revenue may adopt rules for

27  establishing informal conference procedures within the

28  department for resolution of disputes relating to assessment

29  of taxes, interest, and penalties and the denial of refunds,

30  and for informal hearings under ss. 120.569 and 120.57(2).

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    Florida Senate - 1998                           CS for SB 1698
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  1         (2)(a)  The executive director of the department or his

  2  or her designee is authorized to enter into a written closing

  3  agreements agreement with any taxpayer settling or

  4  compromising the taxpayer's liability for any tax, interest,

  5  or penalty assessed under any of the chapters specified in s.

  6  72.011(1). Such agreements shall be in writing when the amount

  7  of tax, penalty, or interest compromised exceeds $30,000 or

  8  for lesser amounts when the department deems it appropriate or

  9  when requested by the taxpayer. When such a written closing

10  agreement has been approved by the department and signed by

11  the executive director or his or her designee and the

12  taxpayer, it shall be final and conclusive; and, except upon a

13  showing of fraud or misrepresentation of material fact or

14  except as to adjustments pursuant to ss. 198.16 and 220.23, no

15  additional assessment may be made by the department against

16  the taxpayer for the tax, interest, or penalty specified in

17  the closing agreement for the time period specified in the

18  closing agreement, and the taxpayer shall not be entitled to

19  institute any judicial or administrative proceeding to recover

20  any tax, interest, or penalty paid pursuant to the closing

21  agreement.  The department is authorized to delegate to the

22  executive director the authority to approve any such closing

23  agreement resulting in a tax reduction of $100,000 or less.

24         Section 4.  Paragraph (c) is added to subsection (2) of

25  section 220.222, Florida Statutes, to read:

26         220.222  Returns; time and place for filing.--

27         (2)

28         (c)  For purposes of this subsection, a taxpayer is not

29  in compliance with the requirements of s. 220.32 if the

30  taxpayer underpays the required payment by more than the

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    Florida Senate - 1998                           CS for SB 1698
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  1  greater of $2000 or 30 percent of the tax shown on the return

  2  when filed.

  3         Section 5.  Subsection (1) of section 624.515, Florida

  4  Statutes, is amended to read:

  5         624.515  State Fire Marshal regulatory assessment and

  6  surcharge; levy and amount.--

  7         (1)(a)  In addition to any other license or excise tax

  8  now or hereafter imposed, and such taxes as may be imposed

  9  under other statutes, there is hereby assessed and imposed

10  upon every domestic, foreign, and alien insurer authorized to

11  engage in this state in the business of issuing policies of

12  fire insurance, a regulatory assessment in an amount equal to

13  1 percent of the gross amount of premiums collected by each

14  such insurer on policies of fire insurance issued by it and

15  insuring property in this state. The assessment shall be

16  payable annually on or before March 1 to the Department of

17  Revenue by the insurer on such premiums collected by it during

18  the preceding calendar year.

19         (b)  When it is impractical, due to the nature of the

20  business practices within the insurance industry, to determine

21  the percentage of fire insurance contained within a line of

22  insurance written by an insurer on risks located or resident

23  in Florida, the Department of Revenue may establish by rule

24  such percentages for the industry. The Department of Revenue

25  may also amend the percentages as the insurance industry

26  changes its practices concerning the portion of fire insurance

27  within a line of insurance.

28         Section 6.  Subsection (3) of section 896.102, Florida

29  Statutes, is amended to read:

30         896.102  Currency more than $10,000 received in trade

31  or business; report required; noncompliance penalties.--

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    Florida Senate - 1998                           CS for SB 1698
    301-2067A-98




  1         (3)  The Department of Revenue may adopt rules and

  2  guidelines to administer and enforce these reporting

  3  requirements.

  4         Section 7.  This act shall take effect July 1, 1998.

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  6          STATEMENT OF SUBSTANTIAL CHANGES CONTAINED IN
                       COMMITTEE SUBSTITUTE FOR
  7                             SB 1698

  8

  9  This committee substitute adds an issue to the bill beyond the
    approval of current Department of Revenue rules. With respect
10  to taxation of trusts, it provides that trusts are not subject
    to intangibles tax if the settlor is not a Florida resident.
11  It also provides a higher threshold than provided in current
    rules before penalizing taxpayers that underpay their
12  estimated corporate income tax.

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