1 | A bill to be entitled |
2 | An act relating to capital formation for infrastructure |
3 | projects; amending ss. 288.9621, 288.9622, and 288.9623, |
4 | F.S.; conforming a short title, revising legislative |
5 | findings and intent, and providing definitions for the |
6 | Florida Capital Formation Act; conforming cross- |
7 | references; creating s. 288.9627, F.S.; providing for |
8 | creation of the Florida Infrastructure Fund Partnership; |
9 | providing the partnership's purpose and duties; providing |
10 | for management of the partnership by the Florida |
11 | Opportunity Fund; authorizing the fund to lend moneys to |
12 | the partnership; requiring the partnership to raise funds |
13 | from investment partners; providing for commitment |
14 | agreements with and issuance of certificates to investment |
15 | partners; authorizing the partnership to invest in certain |
16 | infrastructure projects; requiring the partnership to |
17 | submit an annual report to the Governor and Legislature; |
18 | prohibiting the partnership and the fund from pledging the |
19 | credit or taxing power of the state or its political |
20 | subdivisions; prohibiting the partnership from investing |
21 | in projects with or accepting investments from certain |
22 | companies; creating s. 288.9628, F.S.; creating the |
23 | Florida Infrastructure Investment Trust; providing for |
24 | powers and duties, a board of trustees, and an |
25 | administrative officer of the trust; providing for the |
26 | trust's issuance of certificates to investment partners |
27 | who invest in the partnership; specifying that the |
28 | certificates are redeemable for tax credits under certain |
29 | conditions; authorizing the trust to charge fees; limiting |
30 | the amount of tax credits issued; providing for the |
31 | redemption or sale of certificates; providing for the |
32 | issuance of the tax credits by the Department of Revenue; |
33 | specifying the taxes against which the credits may be |
34 | applied; limiting the period within which tax credits may |
35 | be used; providing for the state's obligation for use of |
36 | the tax credits; limiting the liability of the fund; |
37 | requiring the department to provide a certain written |
38 | assurance to the trust under certain circumstances; |
39 | amending s. 213.053, F.S.; authorizing the department to |
40 | provide tax credit information to the partnership and the |
41 | trust; providing an effective date. |
42 |
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43 | Be It Enacted by the Legislature of the State of Florida: |
44 |
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45 | Section 1. Section 288.9621, Florida Statutes, is amended |
46 | to read: |
47 | 288.9621 Short title.-This part Sections 288.9621-288.9625 |
48 | may be cited as the "Florida Capital Formation Act." |
49 | Section 2. Subsections (1) and (2) of section 288.9622, |
50 | Florida Statutes, are amended to read: |
51 | 288.9622 Findings and intent.- |
52 | (1) The Legislature finds and declares that there is a |
53 | need to increase the availability of seed capital and early |
54 | stage venture equity capital for emerging companies in the |
55 | state, including, without limitation, enterprises in life |
56 | sciences, information technology, advanced manufacturing |
57 | processes, aviation and aerospace, and homeland security and |
58 | defense, as well as other strategic technologies and |
59 | infrastructure funding. |
60 | (2) It is the intent of the Legislature that this part ss. |
61 | 288.9621-288.9625 serve to mobilize private investment in a |
62 | broad variety of venture capital partnerships in diversified |
63 | industries and geographies; retain private sector investment |
64 | criteria focused on rate of return; use the services of highly |
65 | qualified managers in the venture capital industry regardless of |
66 | location; facilitate the organization of the Florida Opportunity |
67 | Fund as an investor in seed and early stage businesses, |
68 | infrastructure projects, venture capital funds, infrastructure |
69 | funds, and angel funds; and precipitate capital investment and |
70 | extensions of credit to and in the Florida Opportunity Fund. |
71 | Section 3. Section 288.9623, Florida Statutes, is amended |
72 | to read: |
73 | 288.9623 Definitions.- As used in this part, the term ss. |
74 | 288.9621-288.9625: |
75 | (1) "Board" means the board of directors of the Florida |
76 | Opportunity Fund. |
77 | (2) "Certificate" means a contract between the trust and |
78 | an investment partner under which the partner, under certain |
79 | conditions, may redeem such certificate for a tax credit to |
80 | guarantee the partner's investment in the partnership. |
81 | (3) "Commitment agreement" means a contract between the |
82 | partnership and an investment partner under which the partner |
83 | commits to providing a specified amount of investment capital in |
84 | exchange for an ownership interest in the partnership. |
85 | (4)(2) "Fund" means the Florida Opportunity Fund. |
86 | (5) "Infrastructure project" means a capital project in |
87 | the state for a facility or other infrastructure need of the |
88 | state, a county, or a municipality with respect to any of the |
89 | following: water or wastewater system, communication system, |
90 | power system, transportation system, renewable energy system, |
91 | ancillary or support system for any of these types of projects, |
92 | or other strategic infrastructure of the state, the county, or |
93 | the municipality. |
94 | (6) "Investment partner" or "partner" means a person, |
95 | other than the partnership, the fund, or the trust, who |
96 | purchases an ownership interest in the partnership. |
97 | (7) "Partnership" means the Florida Infrastructure Fund |
98 | Partnership. |
99 | (8) "Tax credit" means a credit issued against the taxes |
100 | specified in s. 288.9628(7)(b). |
101 | (9) "Trust" means the Florida Infrastructure Investment |
102 | Trust. |
103 | Section 4. Section 288.9627, Florida Statutes, is created |
104 | to read: |
105 | 288.9627 Florida Infrastructure Fund Partnership; |
106 | creation; duties.- |
107 | (1) The Florida Opportunity Fund shall facilitate the |
108 | creation of the Florida Infrastructure Fund Partnership, which |
109 | shall be organized and operated under chapter 620 as a private, |
110 | for-profit limited partnership or limited liability partnership |
111 | with the fund as a general partner. The partnership shall manage |
112 | its business affairs and conduct business consistent with its |
113 | organizing documents and the purposes described in this section. |
114 | However, the partnership is not an instrumentality of the state. |
115 | (2) The primary purpose of the partnership is to raise |
116 | investment capital and invest the capital in infrastructure |
117 | projects in the state that promote the economic development of |
118 | the state, a county, or a municipality. |
119 | (3)(a) The fund, as a general partner of the partnership, |
120 | shall manage the partnership's business affairs, including, but |
121 | not limited to: |
122 | 1. Hiring one or more investment managers to assist with |
123 | management of the partnership. |
124 | 2. Soliciting and negotiating the terms of, contracting |
125 | for, and receiving investment capital with the assistance of the |
126 | investment managers or other service providers. |
127 | 3. Receiving investment returns. |
128 | 4. Disbursing returns to investment partners. |
129 | 5. Approving investments in order to provide financial |
130 | returns together with strategic returns designed to satisfy the |
131 | state's, the county's, or the municipality's infrastructure |
132 | needs; result in a significant potential to create or retain |
133 | jobs in this state; and further diversify the state's economy. |
134 | 6. Engaging in other activities necessary to operate the |
135 | partnership. |
136 | (b) The fund may lend up to $350,000 to the partnership to |
137 | pay the initial expenses of organizing the partnership and |
138 | soliciting investment partners. |
139 | (4)(a) The partnership shall raise funds from investment |
140 | partners for investment in infrastructure projects in the state |
141 | by entering into commitment agreements with such partners on |
142 | terms approved by the fund's board. |
143 | (b) The Florida Infrastructure Investment Trust shall, |
144 | pursuant to s. 288.9628, concurrently with the execution of a |
145 | commitment agreement with an investment partner, issue a |
146 | certificate redeemable for a contingent tax credit to guarantee |
147 | the partner's investment in the partnership. |
148 | (c) The partnership shall provide a copy of each |
149 | commitment agreement to the trust upon execution of the |
150 | agreement by all parties. |
151 | (d) The partnership may enter into commitment agreements |
152 | with investment partners beginning July 1, 2010. The total |
153 | principal investment payable to the partnership under all |
154 | commitment agreements, and the corresponding amount of the |
155 | certificates issued by the trust under s. 288.9628, may not |
156 | exceed the total aggregate amount of $350 million. However, if |
157 | the partnership does not obtain commitment agreements totaling |
158 | at least $75 million by December 1, 2011, the partnership must |
159 | cancel any executed agreement and return the investment capital |
160 | of each investment partner who executed an agreement. |
161 | (5)(a) The partnership may only invest in an |
162 | infrastructure project: |
163 | 1. That fulfills a critical infrastructure need of the |
164 | state. |
165 | 2. That raises enough equity or debt capital from other |
166 | sources so that the total amount invested in the project is at |
167 | least twice the amount invested by the partnership. |
168 | 3. For which legal measures exist, appropriate to the |
169 | individual project, to ensure that the project is not |
170 | fraudulently closed to the detriment of the residents of the |
171 | state. |
172 | (b) The partnership may not invest more than 20 percent of |
173 | its total available investment capital in any single |
174 | infrastructure project. |
175 | (6) The partnership may only invest in an infrastructure |
176 | project based on an evaluation of the following: |
177 | (a) A written business plan for the project, including all |
178 | expected revenue sources. |
179 | (b) The likelihood of the project's attracting operating |
180 | capital from investment partners, grants, or other lenders. |
181 | (c) The management team for the proposed project. |
182 | (d) The project's potential for job creation in the state. |
183 | (e) The financial resources of the entity proposing the |
184 | project. |
185 | (f) The existence of reasonable safeguards to ensure that |
186 | the project provides a continuing benefit for residents of the |
187 | state. |
188 | (g) Other factors not inconsistent with this section that |
189 | are deemed by the partnership as relevant to the likelihood of |
190 | the project's success. |
191 | (7) By December 1 of each year beginning in 2010, the |
192 | partnership shall submit an annual report of its activities to |
193 | the Governor, the President of the Senate, and the Speaker of |
194 | the House of Representatives. The annual report must include, at |
195 | a minimum: |
196 | (a) An accounting of the amounts of investment capital |
197 | raised and disbursed by the partnership and the progress of the |
198 | partnership, including the progress of each infrastructure |
199 | project in which the partnership has invested. |
200 | (b) A description of the benefits to the state that result |
201 | from the partnership's investments, including a list of |
202 | infrastructure projects; the benefits of those projects to the |
203 | state, the county, or the municipality; the number of businesses |
204 | and associated industries positively affected; the number, |
205 | types, and average annual wages of the jobs created or retained; |
206 | and the positive impact on the state's economy. |
207 | (c) Independently audited financial statements, including |
208 | statements that show receipts and expenditures during the |
209 | preceding fiscal year for the operational costs of the |
210 | partnership. |
211 | (8) The partnership and the fund may not pledge the credit |
212 | or taxing power of the state or any political subdivision |
213 | thereof and may not make their debts payable from any moneys or |
214 | resources except those of the partnership or the fund. An |
215 | obligation of the partnership or the fund is not an obligation |
216 | of the state or any political subdivision thereof but is an |
217 | obligation of the partnership or the fund, payable exclusively |
218 | from the partnership's or the fund's resources. |
219 | (9) The partnership may not invest in an infrastructure |
220 | project with, or accept investment capital from, a company |
221 | described in s. 215.472 or a scrutinized company as defined in |
222 | s. 215.473. The entity owning an infrastructure project in which |
223 | the partnership has invested must provide reasonable assurances |
224 | to the partnership that the entity will not provide such company |
225 | or scrutinized company with an ownership interest in the |
226 | infrastructure project. |
227 | Section 5. Section 288.9628, Florida Statutes, is created |
228 | to read: |
229 | 288.9628 Florida Infrastructure Investment Trust; |
230 | creation; duties; issuance of certificates; applications for tax |
231 | credits.- |
232 | (1)(a) There is created the Florida Infrastructure |
233 | Investment Trust, which shall be organized as a state |
234 | beneficiary public trust to be administered by a board of |
235 | trustees. The powers and duties of the board of trustees under |
236 | this section are deemed to be performed for essential public |
237 | purposes. |
238 | (b) The board of trustees shall consist of the Chief |
239 | Financial Officer, the director of the Office of Tourism, Trade, |
240 | and Economic Development, and the vice chair of Enterprise |
241 | Florida, Inc., or their designees. The board of trustees shall |
242 | appoint an administrative officer who may act on behalf of the |
243 | trust under the direction of the board of trustees. |
244 | (c) Members of the board of trustees and its |
245 | administrative officer shall serve without compensation. Neither |
246 | a member nor the administrative officer may have a financial |
247 | interest in any investment partner. |
248 | (2) The trust may hire consultants, retain professional |
249 | services, issue certificates, sell certificates in accordance |
250 | with paragraph (5)(b), expend funds, invest funds, contract, |
251 | bond or insure against loss, or perform any other act necessary |
252 | to administer this section. |
253 | (3)(a) The trust shall, pursuant to s. 288.9627 and this |
254 | section, issue certificates redeemable for contingent tax |
255 | credits to investment partners who make equity investments in |
256 | the Florida Infrastructure Fund Partnership. |
257 | (b) The trust may seek reimbursement of its reasonable |
258 | costs and expenses from the partnership by charging a fee for |
259 | the issuance of certificates to investment partners of up to |
260 | 0.25 percent of the aggregate investment capital committed to |
261 | the partnership by the investment partners who are issued |
262 | certificates. |
263 | (c) All certificates issued by the trust may not exceed |
264 | the total aggregate amount specified in s. 288.9627(4)(d). |
265 | (d) A certificate may only be issued concurrently with a |
266 | commitment agreement between the investment partner and the |
267 | partnership. A certificate issued by the trust must include a |
268 | specific calendar year maturity date designated by the trust of |
269 | at least 12 years after issuance. A contingent tax credit may |
270 | not be claimed or redeemed except by an investment partner or |
271 | purchaser in accordance with this section and the terms of a |
272 | certificate issued by the trust. |
273 | (e) Once the total amount of the investment capital |
274 | committed by an investment partner in his or her commitment |
275 | agreement is provided to the partnership by the partner, the |
276 | certificate is binding, and the partnership, the trust, and the |
277 | Department of Revenue may not modify, terminate, or rescind the |
278 | certificate. |
279 | (4)(a) The partnership shall provide written notice to |
280 | each investment partner if, on the maturity date of his or her |
281 | certificate, the partner's net capital investment is greater |
282 | than zero. The notice must include, at a minimum: |
283 | 1. A good faith estimate of the fair market value of the |
284 | partnership's assets as of the date of the notice. |
285 | 2. The total capital investment of all investment partners |
286 | as of the date of the notice. |
287 | 3. The total amount of distributions received by the |
288 | investment partners. |
289 | 4. The amount of the tax credit the investment partner is |
290 | entitled to be issued by the Department of Revenue. |
291 |
|
292 | For purposes of this section, an investment partner's net |
293 | capital investment is an amount equal to the difference between |
294 | the total investment capital actually advanced by the investment |
295 | partner to the partnership and the amount of the aggregate |
296 | actual distributions received by the investment partner. |
297 | (b) The partnership shall concurrently provide a copy of |
298 | each investment partner's notice to the trust. |
299 | (c) Upon receipt of the notice from the partnership, each |
300 | affected investment partner may make a one-time election to: |
301 | 1. Have a tax credit issued to the investment partner; |
302 | 2. If the investment partner does not have a tax liability |
303 | for any of the taxes specified in paragraph (7)(b), have the |
304 | trust sell the partner's certificate on his or her behalf with |
305 | the proceeds of the sale to be paid to the partner by the trust; |
306 | or |
307 | 3. Maintain the investment partner's investment in the |
308 | partnership. |
309 | (d) Except as provided in paragraph (6)(d), the election |
310 | made by an investment partner under paragraph (c) is final and |
311 | may not be revoked or modified. |
312 | (e) An investment partner must provide written notice to |
313 | the partnership and the trust of his or her election within 30 |
314 | days after his or her receipt of the notice from the |
315 | partnership. If an investment partner fails to provide notice |
316 | within 30 days, the investment partner is deemed to have elected |
317 | to maintain his or her investment in the partnership under |
318 | subparagraph (c)3. |
319 | (5)(a) If an investment partner elects to have a tax |
320 | credit issued to him or her, the trust shall apply to the |
321 | Department of Revenue on the partner's behalf for issuance of |
322 | the tax credit in his or her name. In order to receive the tax |
323 | credit, the investment partner must agree in writing to transfer |
324 | his or her ownership interest in the partnership to the fund. |
325 | (b) If an investment partner elects to have the trust sell |
326 | his or her certificate, the trust shall exercise its best |
327 | efforts to sell the certificate. In order to receive the |
328 | proceeds from the trust's sale of the certificate, the |
329 | investment partner must agree in writing to transfer his or her |
330 | ownership interest in the partnership to the fund. A purchaser's |
331 | payment for the certificate, or any portion thereof, shall be |
332 | made to the trust on behalf of the investment partner or, upon |
333 | the partner's request, directly to the investment partner. The |
334 | trust may sell a certificate in an amount that does not exceed |
335 | the lesser of: |
336 | 1. The amount of the certificate issued to the investment |
337 | partner; or |
338 | 2. The amount necessary to yield proceeds to the |
339 | investment partner equal to his or her net capital investment as |
340 | of the date of the partnership's notice, except that the |
341 | aggregate amount of a certificate sold under this subparagraph |
342 | may not exceed 107 percent of the investment partner's net |
343 | capital investment. |
344 | (6)(a) Within 30 days after receipt of an investment |
345 | partner's election to be issued a tax credit under paragraph |
346 | (5)(a), or within 30 days after the sale of a partner's |
347 | certificate under paragraph (5)(b), the trust shall apply to the |
348 | Department of Revenue for issuance of the tax credit on behalf |
349 | of the partner or on behalf of the certificate's purchaser, as |
350 | applicable. However, the trust's failure to timely submit an |
351 | application to the Department of Revenue does not affect the |
352 | investment partner's or certificate purchaser's eligibility for |
353 | the tax credit. |
354 | (b) The trust's application for a tax credit must include |
355 | the partnership's certification of the amount of tax credit to |
356 | be issued, the identity of the taxpayer to whom the tax credit |
357 | is to be issued, and the tax against which the credit shall be |
358 | applied. The Department of Revenue shall issue the tax credit |
359 | within 30 days after receipt of a timely and complete |
360 | application. |
361 | (c) If an investment partner's certificate is sold by the |
362 | trust under paragraph (5)(b) to more than one purchaser, the |
363 | Department of Revenue shall issue tax credits to such purchasers |
364 | in such amounts as designated by the trust in the application. |
365 | (d) The trust shall provide the investment partner with |
366 | written notice if the trust is unable to sell the partner's |
367 | certificate within 90 days after the partner's election. Within |
368 | 30 days after receipt of such notice, the investment partner |
369 | may: |
370 | 1. Revoke his or her prior election and make a new |
371 | election under paragraph (4)(c); or |
372 | 2. Modify the election and have a tax credit issued to him |
373 | or her for the amount of any unsold credit. Within 30 days after |
374 | such modified election, the trust shall apply to the Department |
375 | of Revenue in accordance with paragraph (a) for issuance of tax |
376 | credits on behalf of the investment partner in the amount of any |
377 | unsold credit and on behalf of the purchasers in the amount of |
378 | their purchased credit. |
379 | (7)(a) The amount of the tax credits certified to the |
380 | Department of Revenue may not exceed the investment partner's |
381 | net capital investment. However, the amount of tax credits that |
382 | may be claimed for a certificate in a calendar year may not |
383 | exceed 25 percent of the amount for which the certificate is |
384 | issued. |
385 | (b) A tax credit issued by the Department of Revenue under |
386 | this section may be used by the owner of the credit as an offset |
387 | against any taxes owed to the state under chapter 212, chapter |
388 | 220, or chapter 624. The offset may be applied by the owner on |
389 | any return for an eligible tax due on or after the date that the |
390 | credit is issued by the Department of Revenue but within 7 years |
391 | after the credit is issued. The owner of the tax credit may |
392 | elect to have the amount authorized in the credit, or any |
393 | portion thereof, claimed as a refund of taxes paid rather than |
394 | applied as an offset against eligible taxes, if such election is |
395 | made within 7 years after the credit is issued. |
396 | (c) To the extent that a tax credit issued under this |
397 | section is used by its owner either as a credit against taxes |
398 | due or to obtain payment from the state, the amount of such |
399 | credit becomes an obligation to the state by the partnership, |
400 | secured exclusively by the ownership interest transferred to the |
401 | fund by the investment partner whose investment generated the |
402 | tax credit. In such case, the state's recovery is limited to |
403 | such forfeited ownership interest. The Department of Revenue |
404 | shall account for tax credits used under this section and make |
405 | such information available to the partnership. The fund, as |
406 | general partner, is not liable to the state for repayment of the |
407 | used tax credits from the fund's separate assets unrelated to |
408 | its interest in the partnership. |
409 | (8) The Department of Revenue, upon the request of the |
410 | trust, shall provide the trust with a written assurance that the |
411 | certificates issued by the trust will be honored by the |
412 | Department of Revenue as provided in this section. |
413 | Section 6. Paragraph (z) is added to subsection (8) of |
414 | section 213.053, Florida Statutes, to read: |
415 | 213.053 Confidentiality and information sharing.- |
416 | (8) Notwithstanding any other provision of this section, |
417 | the department may provide: |
418 | (z) Information relative to tax credits under ss. 288.9627 |
419 | and 288.9628 to the Florida Infrastructure Fund Partnership and |
420 | the Florida Infrastructure Investment Trust. |
421 |
|
422 | Disclosure of information under this subsection shall be |
423 | pursuant to a written agreement between the executive director |
424 | and the agency. Such agencies, governmental or nongovernmental, |
425 | shall be bound by the same requirements of confidentiality as |
426 | the Department of Revenue. Breach of confidentiality is a |
427 | misdemeanor of the first degree, punishable as provided by s. |
428 | 775.082 or s. 775.083. |
429 | Section 7. This act shall take effect July 1, 2010. |