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Monday, February 27, 2017

Having Your Cake and Eating It

                                  Having Your Cake and Eating It
By Albert B Kelly

At first glance, having a big box store chain like a Walmart or a Lowe’s decide to come into town would seem to be mostly a beneficial thing. With the new jobs such stores promise and the anticipated boost to the tax base, it seems like a no lose proposition.

But there’s another aspect to having these big box store chains that many small and mid-size communities don’t often have a chance to consider and it has to do with tax assessments. You would think that the issue of tax assessments would be fairly straight forward.

When one of these big box chains builds a multi-million dollar store in a community, you just assume that the property taxes they will pay would be what you’d expect with a new multi-million dollar facility which factors in everything from construction costs, to land value, to the value of a lease.

But it’s not nearly as straight forward as that. These days, many big box chains lower their tax obligation using a “dark store” tactic to drastically drive down assessments. A glaring example of the “dark store” at work comes out of Michigan courtesy of the Institute for Local Self-Reliance.

Several years ago, Lowe’s built a $10 million store in Marquette and the taxable value was assessed at $5.2 million. After a series of appeals using the “dark store” argument, Lowe’s drove the assessed value down to $1.5 million a few short years later. The dark store argument comes down to “comparable value”.

In the case of the big box chains, they argue that each store is designed to be “functionally obsolete” and that each is a special use structure, custom built, and not intended for reselling or leasing in the market. So when it comes to comparable value, the only thing they claim you can compare it to is a vacant empty “dark store”. 

Now you might think that if one big box chain decided to leave a specific location, another similar retailer might want to fill the space.

You would think that, but the other things at play here are non-compete clauses and deed restrictions. These big box chains place deed restrictions on their new properties limiting how the building can be used by a future occupant.

These restrictions pretty much kill most other potential retail at the site, a site generally zoned for retail, so it either remains empty or gets used for something like indoor batting cages. Either way, it drastically lowers the value of the property and perhaps impacts those nearby.

These tactics are not confined to places like Michigan. The trend is spreading around the country and if it’s not happening here in NJ in any sizable way at present, it’s likely only a matter of time; whether a casino or a Walmart or a Lowe’s.

These are important considerations because if communities are expending serious resources expanding roads and building out infrastructure to accommodate big box chains earning tens of millions in annual sales, then the community is entitled to have an assessment reflective of this size and heft.

This is especially true in light of how the big box chains tend to impact the independent stores and the mom and pops that usually get crushed when the big guys roll into town.

What the big box chains should not be able to do is proactively place deed restrictions on a property and then turn around argue that these very same deed restrictions they’ve insisted on should now result in the store being “functionally obsolete” and assessed that way- having your cake and eating it to.

Communities can’t be left in a position where they anticipate revenues only to have that number reduced by 50%, 60% or more. Nor can communities be in a position where an appeal by a mega-chain results in them having to return huge chunks of revenue in a given year.

When it comes to the big box chains, it may be necessary for the Division of Taxation to provide more clarity on valuation. At the very least, these deed restrictions and “non-compete” clauses should not factor into determining comparable value since it was the chain that insisted on it in the first place.

Whatever may come, communities need to carefully consider all of the implications of hosting one of these big box chains beyond just the number of jobs and the initial hit to the ratable base- future budgets may well depend on it.