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Staff Report
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Report To: Council
Date of Meeting: April 14, 2020 Report Number: FND-008-20
Submitted By: Trevor Pinn, Director of Finance/Treasurer
Reviewed By:
File Number:
Andrew C. Allison, CAO
Resolution#: C-168-20
By-law Number:
Report Subject: COVID-19 Financial Support Program Options
Recommendations:
1. That Report FND-008-20 be received;
2. That Director of Finance continue to work with local area treasurers and the Region
of Durham to develop a sustainable consistent approach for support those impacted
by the COVID-19 pandemic;
3. That the Director of Finance and the Director of Community Services create a new
grant program, the "Community COVID Support Grant Program" modelled after the
existing Community Grants Program specifically to target relief to businesses and
residents effected by COVID-19;
4. That the Community COVID Support Grant Program be funded from the Tax Rate
Stabilization Reserve Fund up to $100,000; and
5. That staff report back to Council at the earlier of the first available meeting after the
Province's emergency declaration is lifted or July 6, 2020.
Municipality of Clarington
Report FND-008-20
Report Overview
Page 2
The COVID-19 pandemic has had an undeniable impact on our economy, residents and
businesses. Council has asked for a "property tax relief program for both businesses and
individuals." The Municipality's ability to provide tax relief is limited by the Municipal Act,
2001 and bonusing rules limit our ability to provide support to businesses.
Staff are recommending that the Municipality provide relief to taxpayers through a new
community grant program that will provide support to eligible organizations that are assisting
those impacted by COVID-19. While the support does not directly impact the tax accounts
of those impacted, it would provide other support which could ease the burden those
impacted by COVID-19 are facing.
Staff will continue to work with other local area municipalities and the Region of Durham on
other tax relief or financial support programs which may more directly impact taxpayers.
1. Background
Property Tax Relief at March 23, 2020
1.1 At the Council meeting of March 23, 2020, Council approved the tax relief measures
outlined in report FND-007-20 which included a 60-day waiver of penalties and interest
(May 1, 2020 and June 1, 2020) starting after the April 23, 2020 due date, waiving of
service fees and delay in the due date for the June installment of taxes by one month.
1.2 Municipalities within the Region of Durham passed similar measures as mentioned
above. Area treasurers, including the Regional Treasurer, met and continue to meet to
ensure that municipalities are providing similar relief throughout the Region.
1.3 Historically, the Region of Durham will only provide tax relief or grants for its portion of
taxes if all the local municipalities adopt similar programs. This prevents a shift of taxes
from one municipality to another and treats all regional taxpayers equitably. This is a
key reason why the area treasurers meet to discuss recommended responses to the
COVID-19 pandemic to ensure that we are all taking similar approaches and maximizing
the relief that can be sought.
1.4 At the March 23, 2020 meeting, Council requested that staff report back to Council on
April 14, 2020 on a "Property Tax Relief Program for both businesses and individuals"
Legislative Ability to Write-off Taxes
1.5 Section 354 of the Municipal Act, 2001 states that "Taxes shall not be written off except
in accordance with this section." The section goes on to provide three times when the
Treasurer of a local municipality shall remove unpaid taxes from the tax roll:
Municipality of Clarington
Report FND-008-20
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• The council of the local municipality, on the recommendation of the treasurer writes off
the taxes as uncollectible;
• The taxes are no longer payable as a result of tax relief under section 319, 345, 357
358, 362,364,365,365.1 or 365.2 or a decision of any court; or
The taxes are no longer payable because the tax liability arose as result of the
assessment of land under subsection 33(1) of the Assessment Act for a period during
which a regulation made under subsection 33 (1.1) of that Act provides that subsection
33(1) of that Act does not apply to land.
1.6 At this point, it is too early to tell if there are any taxes which are uncollectible given the
variety of tools that are available for collection and the allowed timeframe for collection.
Historically in Clarington, the provision for uncollectible taxes has been used for small
value write-offs where the cost to try and collect outweighs the actual amount
outstanding.
1.7 Section 319 of the Municipal Act, 2001 does not apply to the Municipality of Clarington
as it applies to a municipality other than a lower -tier municipality. This section provides
relief to low-income seniors and low-income persons with disabilities. The relief is in the
form of a tax deferral or cancellation of a tax increase on residential property. Any relief
under this section is determined by the Region of Durham.
1.8 Section 345 of the Municipal Act, 2001 relates to late payment charges for the non-
payment of taxes or any instalment by the due date. The local municipality shall cancel
or refund late payment charges for penalties and interest on overcharges of taxes
arising as a result of errors or changes (an assessment change, property class change
or allocation of property class change). Relief as a result of COVID-19 would not be
applicable under this section of the Act.
1.9 Section 357 of the Municipal Act, 2001 allows the local municipality to cancel, reduce or
refund all or part of taxes levied on land in respect of which the application is made if:
a. As a result of a change event, as defined by the Assessment Act, during the tax
year, the property or portion of the property is eligible to be reclassified in a different
class of real property which has a lower tax ratio for the taxation year (e.g. a
commercial property becomes a residential property during the year taxes may be
written off);
b. The land has become vacant land or excess land during the year or the preceding
year;
c. The land has become exempt from taxation during the year or preceding year after
the return of the assessment roll for the preceding year;
Municipality of Clarington
Report FND-008-20
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d. During the year or during the preceding year after the return of the assessment roll
i. a building on the land was razed by fire, demolition or otherwise, or
ii. was damaged by fire, demolition or otherwise so as to render it
substantially unusable;
d.1 The applicant is unable to pay taxes because of sickness or extreme poverty;
e. A mobile unit on the land was removed during the year or during the preceding year
after the return of the assessment roll for the preceding year;
A person was overcharged due to a gross or manifest error that is clerical or factual
in nature, including the transposition of figures, a typographical error or similar error
but not an error in judgment in assessing the property; or
g. Repairs or renovations to the land prevented the normal use of the land for a period
of at least three months during the year. (this was removed for years after 2007)
1.10 From the above, the only authority under section 357 would be due to sickness or
extreme poverty. This would be on a case by case basis and would not be, in my
opinion, justification for a broad write-off of taxes. This section could allow for an
application based program for relief, this could be administratively burdensome and
potentially subjective which is why this section is not typically used for tax relief.
1.11 Section 358 of the Municipal Act, 2001 relates to overcharges. Upon application to the
Treasurer of a local municipality, the local municipality may cancel, reduce or refund all
or part of taxes levied on land:
a. In one or both of the two years preceding the year in which the application is
made for any overcharge caused by gross or manifest error in the preparation of
the assessment roll that is clerical or factual in nature;
b. In the year or years in respect of which an assessment is made under section 33
or 34 of the Assessment Act for any overcharge caused by a gross or manifest
error in the preparation of the assessment that is clerical or factual in nature.
1.12 Relief under section 358 would not be applicable in the current situation.
1.13 Section 362 of the Municipal Act, 2001 does not apply to lower -tier municipalities and is
therefore not applicable to the Municipality of Clarington. This section relates to relief
for those properties which are subject to capping on property taxes.
1.14 Section 364 of the Municipal Act, 2001 no longer applies as it related to vacant unit
rebates. This program was ended within the Region of Durham, as well as many
Municipality of Clarington Page 5
Report FND-008-20
municipalities throughout the Province of Ontario, in 2019. This program was available
to commercial and industrial properties which had vacancies of at least 90 consecutive
days.
1.15 Section 365 of the Municipal Act, 2001 the Council of a local municipality may, in any
year, pass a by-law to provide for the cancellation, reduction or refund of taxes levied for
local and school purposes in the year by the council in respect of an eligible property of
any person who makes an application in that year to the municipality for that relief and
whose taxes are considered by the council to be unduly burdensome, as defined in the
by-law.
1.16 Under section 365, eligible properties are those within residential, farm or the managed
forest property class. This would not apply to multi -residential, commercial or industrial
properties. Further, there is no requirement that the upper -tier have the same program,
if they do not the lower tier municipality would be required to pay the upper tier for the
full amount of the taxes.
1.17 Section 365.1 of the Municipal Act, 2001 provides for cancellation of all or a portion of
taxes for municipal and school purposes levied on specified properties (a property for
which a phase two environmental site condition has been conducted) in respect of the
rehabilitation period and/or the development period of the property. This would not be
applicable in this situation. This type of relief is common in attempts to redevelopment
brownfield sites.
1.18 Section 365.2 allows tax reductions for heritage properties outlined in the Municipal Act,
2001. Again, this would be a targeted relief for specified types of properties that are
designated under the Ontario Heritage Act. This would not be COVID-19 related.
1.19 As can be demonstrated from the above, the situations in which a municipality may
provide tax relief are highly prescribed. If Council wished to provide relief for taxpayers
impacted by COVID-19 it would, in my opinion, need to be an application -based relief
under section 357 d.1 or potentially section 365.
1.20 The difficulty with application -based programs would be that there would be an added
layer of administration and this could be subjective unless it is are very clearly
prescribed in who would qualify for assistance.
Ability to Provide Financial Support
1.21 While the request from Council was specific to property tax relief, there may be other
opportunities for the Municipality to provide fiscal support to individuals and businesses.
These other supports are again limited, however in these times, looking outside the box
may provide the best support for those in need.
Municipality of Clarington Page 6
Report FND-008-20
1.22 Section 106 of the Act prohibits a municipality from assisting directly or indirectly any
manufacturing business or other industrial or commercial enterprise through the
granting of bonuses for that purpose.
1.23 The Municipal Act, 2001 provides municipalities general powers, notwithstanding
section 106, to make grants in section 107 of the Act. Grants under this section includes
several powers including guaranteeing loans, providing for use of property, staff, sales
of property at a nominal price or the donation of foodstuffs and merchandise purchased
by the municipality for that purpose. These would be to those organizations that are not
considered a manufacturing business or commercial enterprise.
1.24 Using the above authority, the Municipality could provide financial or in -kind support to
non-profit organizations that support the community. The Municipality's Community
Grants Program is an example of this.
1.25 Providing support or services for small business counselling is permitted under section
108 of the Municipal Act, 2001. This service could include the ability to acquire land and
buildings to provide leased premises to eligible small businesses, provide grants to
corporations, lease land to small businesses.
2. Financial Support Provided by Other Governments
Government of Canada
2.1 Report FND-007-20 outlined several steps that the Government of Canada was taking
to assist taxpayers through COVID-19.
2.2 The Government of Canada further announced on March 27, 2020 that the previously
announced 10% wage subsidy to help small businesses maintain their payroll will be
increased to 75% and backdated to March 15, 2020. This measure is intended to help
small and medium enterprises (SME) keep their staff employed during the COVID
pandemic.
2.3 The Government will guarantee interest free loans of up to $40,000 to businesses from
banks.
2.4 Several tax filing dates have been deferred, including GST/HST returns.
2.5 The Government of Canada's economic response plan is available online and is
changing as more information becomes available.
Municipality of Clarington Page 7
Report FND-008-20
Province of Ontario
2.6 Report FND-007-20 outlined several steps that the Province of Ontario had announced
it was taking to assist taxpayers through COVID-19.
2.7 Since that date the Province provided an economic update, originally intended to be the
Provincial budget, which included a one-time $200-per-child payment to offset school
and daycare closures, doubling support to low-income seniors, deferring OSAP
payments, lowering electricity rates, increasing the Employer Health Tax exemption and
setting aside funds to absorb penalties and interest for businesses that can't cover the
provincially -administered tax burden.
2.8 The Province followed the Government of Canada in deferring the due date for several
taxes and fees including EHT, WSIB and income taxes.
2.9 Tax assessments for 2021 will be frozen at the 2020 assessment value. This provides
stability for property owners in 2021 as there will not be an impact on taxes as a result
of market value phase -in.
2.10 The Province also announced that starting with the June 30, 2020 the deadline for
municipalities to pay the education portion of taxes collected would be pushed back 90
days. This coincides with many municipalities' move to defer due dates/waive penalties
for 60 to 90 days.
Region of Durham
2.11 The Region of Durham has delegated authority to the Regional Treasurer in order to
address certain financial concerns. We are anticipating that the Region will defer the
April 30, 2020 payment due date to June 30 to coincide with the lower tiers' waiver of
penalties and tax on May 1, 2020 and June 1, 2020.
2.12 The Region announced on March 26, 2020 that all water and sewer bill late payment
charges, collection notifications and water shut offs for non-payment have been
suspended. This is like the support provided by other municipalities that have water and
wastewater services.
2.13 The Region will be providing loans to chambers of commerce, including CBOT, to
ensure that these organizations are able to assist businesses with accessing financial
supports from both the Province of Ontario and Government of Canada.
2.14 Region staff have indicated that past practice is that support should only be made if it
benefits and is available to all municipalities. To provide support in any other way would
create a shift of the tax burden between municipalities. Region staff are supportive of a
group response to financial support.
Municipality of Clarington
Report FND-008-20
Other Municipalities
Page 8
2.15 A scan of support offered by other municipalities reveals that most are in line with what
the Municipality of Clarington has already provided. It should be noted that some
municipalities (such as the City of Toronto or the City of London) have included
waivers/deferrals of interest and penalties on water/wastewater bills and utilities. The
Municipality of Clarington does not have control over these utilities and is unable to
provide relief for these services; however as noted above, the Region of Durham has
suspended late payment charges for water and sewer services.
2.16 Most municipalities have waived penalties and interest for approximately 60 days. There
are several where the waiver is 90 days, this is likely to do with timing of the instalment
dates as each municipality sets their own instalment schedule. Durham municipalities
also announced a delay in the first instalment of the final tax due date by one month
which mitigated the potential of two due dates in the same month.
2.17 The City of Markham has announced that no penalties and interest will be charged until
December 31, 2020. Although taxpayers are "urged" to pay on time. This length of time
for a waiver is not advised by staff for several reasons. First, this could serious
jeopardize the Municipality's cash flow as there would be no incentive for taxpayers to
pay on time. Second, the Municipality budgets for approximately $1.25 million in
penalties and interest annually to offset the tax levy, a waiver for the remainder of the
year could result in a significant draw from the tax rate stabilization reserve fund in
2020. It should be noted that no other municipality, that the writer is aware of, has
announced this length of interest/penalty relief.
3. Suggested Support
3.1 It is still very early to determine the full impact of the COVID-19 pandemic on the
economy of Clarington which includes residents and businesses. As we are still within
the pandemic, it is beneficial to defer a decision on further tax relief until we are better
able to determine the financial constraints the Municipality is under.
3.2 Area municipalities, including the Region of Durham, are meeting regularly to determine
the process for tax relief within our authority to do so. If we act on our own, we will not
likely be able to leverage the Region of Durham for financial assistance.
3.3 As the Municipality is restricted in our ability to provide financial or other in -kind support
to enterprises any support should be funneled through eligible organizations. The
Municipality could provide financial support to CBOT to provide small business
counselling services to assist small business in this time of need.
3.4 It is recommended that a new "Community COVID Support Grant Program" be
established. The Director of Finance and Director of Community Services be directed to
Municipality of Clarington
Report FND-008-20
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create the framework and advertise for this program with recommended awards to be
brought back to Council. Staff are suggesting that an initial program of $100,000,
funded from the Tax Rate Stabilization Reserve Fund be established. This program
would provide funding to non-profit organizations to provide community support
programs, including those supporting small -businesses, to those in need as a result of
the COVID-19 pandemic.
3.5 While not directly tax support, by providing support for organizations to assist with
providing food, meals, deliveries and other services we are able to allow the residents
and taxpayers to avoid those costs which is an indirect financial support for our
community.
4. Concurrence
This report has been reviewed by the Director of Community Services who concurs with
the recommendations.
5. Conclusion
It is respectfully recommended that staff be asked to report back at the first available
meeting after the lifting of the emergency declaration or July 6, 2020 whichever is
earlier.
Staff Contact: Trevor Pinn, CPA, CA Director of Finance/Treasurer, 905-623-3379 x.2602 or
tpinn@clarington.net.
Attachments:
Not Applicable
There are no interested parties to be notified of Council's decision.