6484 r
ORDINANCE NO. 6484
AN ORDINANCE OF THE CITY OF ANAHEIM AMENDING
CHAPTER 2.12 (TRANSIENT OCCUPANCY TAX) OF TITLE 2
(TAXES)OF THE ANAHEIM MUNICIPAL CODE TO MODIFY
THE OPERATOR'S COLLECTION DUTIES.
WHEREAS, by the adoption of Ordinance 5305, May 27, 1992; Ordinance 5338, October
27, 1992; Ordinance 5436, August 2, 1994; Ordinance 5495, May 9, 1995; Ordinance 5741,
November 7, 2000; Ordinance 5777, August 28, 2001; and Ordinance 5866, June 17, 2003; the
City Council of the City of Anaheim("City Council")added and amended Chapter 2.12 (Transient
Occupancy Tax) to Title 2 (Taxes) of the Anaheim Municipal Code (the "Code") for the purpose
of imposing a tax for the privilege of occupancy in hotels located within the City of Anaheim
("City"); and
WHEREAS, Chapter 2.12 (Transient Occupancy Tax) is known and referred to as the
"Transient Occupancy Tax Code"; and
WHEREAS, on December 12, 2016, the California Supreme Court issued its opinion in
the case In re Transient Occupancy Tax Cases, 2 Ca1.5th 131 (2016), in response to the petition
for writ of mandate of online travel companies ("OTCs") that were challenging the determination
of the City of San Diego that the OTCs were responsible for paying transient occupancy tax
("TOT") on their service fees; and
WHEREAS, the San Diego ordinance at issue before the California Supreme Court
assessed and calculated the transient occupancy tax obligation as a percentage of the "Rent charged
by the Operator" of the hotel,which is the same basis for assessment and calculation of TOT under
the Anaheim ordinance; and
WHEREAS, the California Supreme Court described the San Diego OTC transactions as
arising out of the "merchant model," whereby the price the hotel charges the OTC for the room is
the wholesale price subject further to a "rate parity" agreement that bars the OTC from selling a
room for a rent lower than a"floor" room rate which the hotel quotes its customers directly; and
WHEREAS, the California Supreme Court held that "To the extent a hotel determines the
markup, such as by contractual rate parity provisions requiring the OTC to quote and charge the
customer a rate not less than what the hotel is quoting on its own website, it effectively 'charges'
that amount, whether or not it ultimately receives or collects any portion of the markup, and that
amount is therefore subject to the tax," and further stated that: "Thus, it is the wholesale room rate
plus the hotel-determined markup, exclusive of any discretionary markup set by the OTC, that is
'charged by the Operator' and subject to the tax"; and
WHEREAS, despite the ruling of the California Supreme Court that TOT is due on the full
amount of the "floor room rate" set and required by hotel operators to be charged by OTCs to hotel
customers (defined in the Anaheim ordinance as "transients"), and despite the applicability of this
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ruling to the Anaheim TOT ordinance, the City believes that Anaheim hotel operators have not in
every case remitted TOT to Anaheim on this full amount of"rent," but may have remitted TOT in
some instances only on the lower wholesale room rate, resulting in an underpayment of TOT to
the City; and
WHEREAS,the California Supreme Court also held that because the San Diego ordinance
imposed the duty to remit the tax solely on "the Operator" it did not allow the city to assess TOT
directly against an OTC, and the Court rejected other arguments that OTC's should be treated as
operators for purposes of TOT collection under the ordinance; and
WHEREAS,the Anaheim hotel operators have advised the City that,in certain transactions
where they have established and required a floor room rate through a rate parity agreement or other
hotel operator-determined mark up, it would assist in facilitating their collection of the full amount
of TOT if payment were to be made by customers directly to the hotel operators; and
WHEREAS, the Anaheim hotel operators have specifically identified those certain
transactions of under-collection of TOT as being limited to circumstances where the hotel operator:
(a) has established and required a floor room rate through a rate parity agreement or other hotel-
determined mark up; and (b) the OTC, rather than the hotel operator, handles the financial
transactions related to the hotel reservations, received the hotel guest's payment, and is listed on
the hotel guest's credit card receipt; and
WHEREAS, the City Council desires to protect and serve its residents, visitors and others
who depend upon the full collection of all properly due City taxes by facilitating efforts by hotel
operators to collect and remit the proper amount of TOT; and
WHEREAS,pursuant to the California Environmental Quality Act(Public Resources Code
Section 21000 et seq.; herein referred to as "CEQA") and the State of California Guidelines for
Implementation of the California Environmental Quality Act(commencing with Section 15000 of
Title 14 of the California Code of Regulations;herein referred to as the "State CEQA Guidelines"),
the City is the "lead agency" for the preparation and consideration of environmental documents
for this ordinance; and
WHEREAS, the City Council finds and determines that this ordinance is not subject to
CEQA pursuant to Sections 15004, 15060(c)(2), 15060(c)(3), and 15061(b)(3) of the State CEQA
Guidelines, because it will not result in a direct or reasonably foreseeable indirect physical change
in the environment,there is no possibility that it may have a significant effect on the environment,
and it is not a "project," as that term is defined in Section 15378 of the State CEQA Guidelines.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF ANAHEIM DOES
ORDAIN AS FOLLOWS:
SECTION I. Sections 2.12.005 and 2.12.020 of Chapter 2.12 (Transient Occupancy Tax)
of Title 2 (Tax) of the Anaheim Municipal Code) shall be, and the same hereby are amended and
restated to read in their entirety as follows:
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2.12.005 DEFINITIONS.
For purposes of this chapter,the following words,terms,phrases, and the derivations and
variants thereof, shall have the meanings given herein:
.010 "Anaheim" or"City" means the City of Anaheim.
.020 "City Auditor" means the Audit Manager of the City.
.021 "Direct Payment"means the payment of rent from a transient directly to an operator
who collects the rent directly from the transient, and shall include where the transient's rent
payment directly to the operator is made or processed using cash, check, credit card, debit
card, or any other direct in-person or electronic payment and collection method, but shall
exclude the Indirect Payment of rent from a transient to a third party who then remits the
rent, in whole or in part, to the operator.
.025 "Fiscal Year" means the period commencing July 1 of one calendar year through
June 30 of the immediately subsequent calendar year.
.030 "Homeless person" means any person who lived or resided in Anaheim
immediately prior to being provided shelter in a hotel by a Qualifying Nonprofit Service
Organization.
.040 "Hotel" means any structure or portion thereof, which is occupied by persons for
lodging or sleeping purposes for periods of less than thirty consecutive days including,
without limitation, any hotel, bachelor hotel, motel, lodging house, rooming house, bed
and breakfast inn,apartment house,dormitory,vacation ownership resort,public or private
club, mobilehome or house trailer at a fixed location, or other similar structure or portion
thereof, and any space, lot, area or site in any trailer court, camp, park, or lot which is
occupied or intended or designed for occupancy by a tent, trailer, recreational vehicle,
mobilehome, motorhome, or other similar conveyance, where such structure, space, lot,
area or site is occupied by persons for lodging or sleeping purposes for periods of less than
thirty consecutive days.
.045 "Indirect Payment" means the payment of rent from a transient directly to a third
party who collects the rent directly from the transient and who then remits the rent,in whole
or in part, to the operator, and shall include where the transient's rent payment directly to
the third party is made or processed using cash, check, credit card, debit card, or any other
direct in-person or electronic payment and collection method, but shall exclude the Direct
Payment of rent from the transient to the operator.
.050 "Operator" means any person, corporation, entity, or partnership which is the
proprietor of the hotel, whether in the capacity of owner, lessee, sublessee, mortgagee in
possession, debtor in possession, licensee or any other capacity. Where the operator
performs its functions through a managing agent of any type or character other than as an
employee, the managing agent shall also be deemed an operator and shall have the same
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duties and liabilities as its principal. Compliance with the provisions of this chapter by
either the principal or managing agent shall constitute compliance by both. For purposes
of the notice and appeal provisions of this chapter only, "operator" shall also include any
managing employee or employee in charge of the hotel.
.060 "Qualifying Nonprofit Service Organization" means any nonprofit service
organization which(a) is a member of the Anaheim Human Services Network, (b) directly
pays the cost of sheltering homeless persons in a hotel and(c)does not directly or indirectly
further any religious purpose by providing such shelter.
.070 "Qualifying Rental Agreement" means and is limited to a written contract signed
by both the landlord and tenant, legally enforceable by either party, for a rental period of
not less than thirty consecutive days. "Qualifying Rental Agreement" shall expressly
exclude: (1) any agreement regardless of length of the rental term which is terminated for
any reason by either party or by mutual consent prior to the thirtieth consecutive day of the
tenancy, or (2) any agreement regardless of the length of the rental term which is for
occupancy of lodging or sleeping space which is not the legal residence or principal
dwelling place of the occupant,or(3)any agreement which would be unlawful or constitute
a violation of law.
.080 "Rent" means the consideration charged by an operator for accommodations,
including without limitation any (1) unrefunded advance rental deposits or (2) separate
charges levied for items or services which are part of such accommodations including, but
not limited to, furniture, fixtures, appliances, linens, towels, non-coin-operated safes, and
maid service. "Rent" shall not include any charge, billing, or account or portion thereof
which the operator finds to be worthless or uncollectible and charged off for tax purposes.
If any such worthless or uncollectible rent is thereafter collected, the amount shall be
considered rent in the month collected and the tax collected shall be included in the next
monthly payment to Anaheim by the operator. "Rent" shall also not include any amount
upon which a sales or use tax is imposed pursuant to Chapter 2.04 of this Code if the
imposition of a tax pursuant to this Chapter 2.12 would be deemed to constitute an
additional sales and use tax conforming to all of the conditions set forth in subdivision (b)
of Section 7203.5 of the Revenue and Taxation Code of the State of California. (Ord. 5777
§ 12; August 28, 2001.)
.090 "Tax" (where such term is not capitalized) means the amounts imposed pursuant
to Section 2.12.010 of this chapter; "Tax" (where such term is capitalized) means 1) the
tax and 2) any applicable interest and penalties imposed by this chapter and 3) any amount
collected by an operator under a representation that it is a tax which is not refunded in
accordance with this chapter.
.100 "Transient" means any person who exercises occupancy, or is entitled to
occupancy,of any room, space,lot,area or site in any hotel by reason of concession,permit,
right of access, license or other agreement whether written or oral. Any such person shall
be deemed to be a transient until the thirtieth consecutive day of such occupancy or right
of occupancy and the tax imposed by this Chapter shall be due upon all rent collected or
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accruing prior to said thirtieth consecutive day unless the occupancy is pursuant to a
Qualifying Rental Agreement. (Ord. 5305 § 1 (part); May 27, 1992: Ord. 5741 § 1;
November 7, 2000.)
2.12.020 OPERATOR'S COLLECTION DUTIES.
.010 Each operator shall collect the tax to the same extent and at the same time as the
rent is collected from every transient. The amount of the rent and the tax thereon shall be
separately stated from all other amounts on all receipts and books of record of the hotel,
and each transient shall be tendered a receipt for payment from the operator with rent and
tax separately stated thereon. No operator shall advertise or state in any manner, directly
or indirectly, that the tax or any part thereof will be assumed or absorbed by the operator
or that the tax will not be added to the rent or that, if added, any part of the tax will be
refunded except in the manner hereinafter provided. Notwithstanding the foregoing
provision of this subsection, nothing contained herein shall require the operator to
separately state the rent and the tax thereon on receipts and books of record or prohibit the
operator from advertising or stating that the tax will be assumed or absorbed by the operator
or that such tax will not be added to the rent, provided such room accommodations
constitute a portion of a collective group of services, privileges, entitlement or benefits
(hereinafter "benefits") which benefits include, at a minimum, room accommodations and
food and beverage services or room accommodations and at least one other benefit having
an ascertainable fair market value (hereinafter "special package") offered for one fixed
charge (hereinafter "special package rate").
Further, as of July 15, 2020,but only in those circumstances where the operator has set and
required a floor room rate that must be charged by a third party to a transient, an operator
shall only collect rent from a transient, and at the same time shall collect the tax on the full
amount charged by the operator,through Direct Payment from the transient to the operator.
Notwithstanding the July 15, 2020 date for the mandatory commencement of the Direct
Payment of rent and tax from the transient to the operator under the circumstances where
the operator has set and required a floor room rate that must be charged by a third party to
a transient, if the terms of a lawful and fully executed contract that was entered into and in
effect between an operator and a third party prior to May 12, 2020 would be impaired by
the Direct Payment requirement of this subsection, the Direct Payment provision shall not
apply to collection of rent under that contract until the earlier of: (1) its renewal,
amendment, or extension; or (2) July 15, 2021. On or before July 15, 2020, any operator
claiming such an impairment of contract shall file with the License Collector a statement
of impairment under penalty of perjury. The burden shall be on the operator to prove and
document its claim of impairment to the reasonable satisfaction of the City in the operator's
filed statement, through provision of the relevant contract, the entry and end dates of the
contract, and an explanation of how the City's Direct Payment requirement impairs the
contract.
.011 In the event the operator fails to separately state the rent and tax from other amounts
on all receipts and books of record, the operator shall file with the License Collector a
statement of each special package rate on a form (hereinafter "Special Package Form") -
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provided by the License Collector. The Special Package Form shall include the special
package rate, and an itemization of the values of the items included, including, at a
minimum, the rent, tax, and any other item. The operator must submit documentation to
substantiate the claimed fair market value of individual items included other than rent and
tax. The License Collector shall mark the date of receipt on the Special Package Form and
review the submitted information to determine if sufficient information is provided to
verify that the numbers are mathematically correct and complies with this chapter. If the
package meets the foregoing requirements, the License Collector shall assign a unique
number to the Special Package Form and return a copy to the operator within fourteen City
business days of receipt. The operator may use the assigned unique number or may assign
the operator's unique name/number to each package and notify the License Collector to
imprint the name/number on the Special Package Form. This unique name/number must
appear on all receipts and books of record whenever the package is sold. If the package
fails to meet the requirements of this Subsection, the License Collector will advise the
operator of any required changes within fourteen City business days. The operator must
either make the required changes and resubmit the Special Package Form or comply with
subsection 2.12.020.010. A new Special Package form must be submitted in the event of
any change in the special package rate or the specified rate (subsection 2.12.020.013), or
other items in the special package which exceeds ten percent and for any new special
package(s) offered/used. Any change of items within the special package constitutes a new
special package. The effective date of the special package rate shall be the date of receipt
by the License Collector if the package is approved.
.012 No Special Package Form shall be accepted for filing unless accompanied by a
filing fee in the amount established by resolution of the City Council.
.013 As to any package sold by the operator for which the License Collector has
approved the package and assigned the unique number, the tax shall apply only to the
amount of rent identified in the Special Package Form (hereinafter "specified rate") until
such time as the License Collector shall inform the operator that the approval is revoked.
.014 In the event an operator fails to comply with subsection 2.12.020.010 and also fails
to file a Special Package Form and obtain approval of a specified rate pursuant to
subsection 2.12.020.011, the portion of the special package rate attributable to the room
accommodations for purposes of determining the tax (hereinafter "imputed rate") shall be
deemed the lesser of(a)the amount collected for the total special package or(b) an amount
equal to the median average double occupancy room rate for such accommodations as
posted in such room pursuant to the requirements of Section 1863 of the Civil Code (or
any successor section). The burden to prove such posted room rates shall be upon the
operator. In the event the operator fails to present satisfactory proof of such rates, such
posted rates shall be deemed the posted rates in effect at the time of the audit.
.015 Notwithstanding subsections 2.12.020.011 and 2.12.020.013, if any audit reveals
that the gross income to the operator attributable to the accommodations portion of such
special package (hereinafter "audited rate") is more than ten percent greater than the
specified rate, the rent for tax purposes shall be the audited rate. In the event subsection
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2.12.020.014 applies and the audited rate is greater than the imputed rate, the rent for tax
purposes shall be the audited rate. The audited rate shall be determined by an audit of a
sample of the special packages sold by the operator within an individual special package
category. The audited rate shall be the amount of the special package rate remaining after
deducting the fair market value of each of the benefits included in the special package rate
other than room accommodations and room tax. Where more than one type of special
package was offered within the audit period, each special package shall be audited
separately for purposes of determining the applicable audited rate. Credits or offsets shall
not be allowed between different special packages. (Ord. 5777 § 12; August 28, 2001)
.020 Any amount charged and collected by the operator from any transient beyond the
period for which the tax is imposed, which amount is in excess of the rent theretofore
charged the transient for the same accommodations and upon which rent tax was imposed
and collected, shall be conclusively deemed collected under the representation by the
operator that such excess amount was tax. If the operator gives such person written notice
prior to the accrual of the obligation therefor that such excess amount constitutes an
increase in the rental rate this subsection shall not apply. The burden to prove such notice
shall be upon the operator.
.030 Whenever an operator who has collected any sum under the representation that it
was tax (which sum was not required to be collected as tax) remits said sum to Anaheim
and thereafter refunds such sum in whole or part, such operator may take the amount of
such refund as a credit against future transient taxes only upon submitting to the License
Collector a statement under penalty of perjury specifying the reasons for the credit and
proof of payment of such refund.
.040 Nothing contained in this chapter shall require the refund by Anaheim to any person
of such sum collected by the operator and remitted to Anaheim even where such sum was
not otherwise required to be collected and remitted.
.050 Nothing contained in this chapter shall be deemed to authorize as a credit against
tax any amount paid by the operator to any tour promoter, travel agent, or third party other
than the transient. Travel agent commissions are an expense of the operator and may not
be deducted from the rent. (Ord. 5305 § 1 (part); May 27, 1992.)
SECTION 2. SEVERABILITY.
The City Council of the City of Anaheim hereby declares that should any section,
paragraph, sentence, phrase, term or word of this ordinance be declared for any reason to be
invalid, it is the intent of the City Council that it would have adopted all other portions of this
ordinance independent of the elimination of any such portion as may be declared invalid. If any
section, subdivision,paragraph, sentence, clause or phrase of this Ordinance is for any reason held
to be invalid or unconstitutional, such decision shall not affect the validity of the remaining
portions of this Ordinance. The City Council hereby declares that it would have passed this
Ordinance, and each section, subdivision, paragraph, sentence, clause and phrase thereof,
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irrespective of the fact that any one (or more) section, subdivision,paragraph, sentence, clause or
phrase had been declared invalid or unconstitutional.
SECTION 3. CERTIFICATION.
The City Clerk shall certify to the passage of this ordinance and shall cause the same to be
printed once within fifteen (15) days after its adoption in the Anaheim Bulletin, a newspaper of
general circulation, published and circulated in the City of Anaheim.
SECTION 4. EFFECTIVE DATE.
This ordinance shall take effect and be in full force thirty (30) days from and after its final
passage. -
THE FOREGOING ORDINANCE was introduced at a regular meeting of the City Council
of the City of Anaheim held on the 12th day of May, 2020, and thereafter passed and adopted at a
regular meeting of said City Council held on the 9th day of June, 2020, by the following roll call
vote:
AYES: Mayor Sidhu and Council Members Faessel, Barnes, Brandman, Moreno,
Kring and O'Neil
NOES: None
ABSENT: None
ABSTAIN: None
CITY 7 ANAHEI
By L
MA Oi7r +Fr I Y OF ANAHEIM
10
ERK OF THE CITY OF ANAHEIM
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CLERK'S CERTIFICATE
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.
CITY OF ANAHEIM )
I, THERESA BASS, City Clerk of the City of Anaheim, do hereby certify that the foregoing is the
original Ordinance No. 6484 introduced at a regular meeting of the City Council of the City of
Anaheim, held on the 12th day of Mav, 2020, and that the same was duly passed and adopted at
a regular meeting of said City Council held on the 9th day of June, 2020, by the following vote of
the members thereof:
AYES: Mayor Sidhu and Council Members Faessel, Barnes, Brandman, Moreno,
Kring, and O'Neil
NOES: None
ABSENT: None
ABSTAIN: None
IN WITNESS WHEREOF, I have hereunto set my hand this 16th of June, 2020.
CITY CLE"K OF THE CITY OF ANAHEIM
(SEAL)
Anaheim Bulletin PROOF OF PUBLICATION
2190 S.Towne Centre Place Suite 100
Anaheim, CA 92806 Legal No. 0011390710
714-796-2209 SUMMARY PUBLICATION
ORDINANCE NO.6484
AN ORDINANCE OF THE CITY OF ANAHEIM AMENDING
CHAPTER 2.12(TRANSIENT OCCUPANCY TAX)OF TITLE 2
5190168 (TAXES)OF THE ANAHEIM MUNICIPAL CODE TO MODIFY
THE OPERATOR'S COLLECTION DUTIES
ANAHEIM,CITY OF/CLERKS OFF The primary purpose of this ordinance is to amend sections 2.12.005
200 S ANAHEIM BLVD STE 217 and 2.12.020 of Chapter 2.12 (Transient Occupancy Tax) of Title 2
(Taxes)of the Anaheim Municipal Code to provide that,whenever a
ANAHEIM, CA 92805-3820 hotel operator has required a minimum amount for a room to be
charged to a hotel guest by a third party,the hotel operator must col-
lect the rent and the corresponding transient occupancy tax directly
from the guest. This requirement would apply to both existing and
future agreements between hotel operators and third parties,subiect
to any operator's right to show that the terms of an existing contract
FILE NO. ORDINANCE NO. 6484 would be impaired by the new law's application to it. For those cur-
rent contracts that would be impaired, the ordinance would apply
nce those current contracts expire,AFFIDAVIT OF PUBLICATION renewed,and in no event afterJuly152021enthey are amended orare.
STATE OF CALIFORNIA, I,Theresa Bass,City Clerk of the City of Anaheim,do hereby certify
that the foregoing is a summary of Ordinance No.6484,which ordi-
SS. nance was introduced at a regular meeting of the City Council of the
County of Orange City of Anaheim on May 12,2020 and was duly passed and adopted at
a regular meeting of the Council on June 9,2020 by the following roll
call vote of the members thereof:
AYES: Mayor Sidhu and Council Members Faessel,Barnes,
Brandman,Moreno,Kring,and O'Neil
I am a citizen of the United States and a resident of the NOES: None
County aforesaid; I am over the age of eighteen years,and
not a party to or interested in the above-entitled matter. I ABSENT: None
am the principal clerk of the Anaheim Bulletin, a ABSTAIN: None
newspaper that has been adjudged to be a newspaper of
general circulation by the Superior Court of the County of The above summary is a brief description of the subiect matter con-
Oran e, State of California, on December 28, 1951, Case sunt in Sectionec text 512 of the Charterinance No. 6f the4,which ofhas been m.prThisared sum-
No.
suant to of the of City Anaheim. This sum-
No. A-21021 in and for the City of Anaheim, County of mary does not include or describe every provision of the ordinance
Orange, State of California; that the notice, of which the and should not be relied on as a substitute for the full text of the ordi-
nance.
annexed is a true printed copy, has been published in To obtain a copy of the full text of the ordinance, please contact the
each regular and entire issue of said newspaper and not in Office of the City Clerk, (714) 765-5166, between 8:00 a.m. and 5:00
p.m.,Monday through Friday.There is no charge for the copy.
any supplement thereof on the following dates,to wit:
Published Anaheim Bulletin June 18,2020 11390710
06/18/2020
I certify(or declare) under the penalty of perjury under the
laws of the State of California that the foregoing is true
and correct:
Executed at Anaheim, Orange County, California, on
Date: June 18,2020.
C
Signature
r.LP1-12/15116 1
CLERK'S CERTIFICATE
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.
CITY OF ANAHEIM )
I, THERESA BASS, City Clerk of the City of Anaheim, do hereby certify that the foregoing is
the original Ordinance No. 6484 and was published in the Anaheim Bulletin on the 18th day
of June, 2020, pursuant to Section 512 of the City Charter of the City of Anaheim.
40111100. _
CITY CLER OF THE CITY OF ANAHEIM
(SEAL)