RE 2015-0825.1
RESOLUTION NO. 2015-0825.1
A RESOLUTION OF THE CITY OF COPPELL, TEXAS, APPROVING THE
TERMS AND CONDITIONS OF A TAX ABATEMENT AGREEMENT BY AND
BETWEEN THE CITY OF COPPELL, TEXAS, AND PANASONIC CORPORATION OF
NORTH AMERICA, A DELAWARE CORPORATION; AUTHORIZING ITS
EXECUTION BY THE MAYOR; AND PROVIDING AN EFFECTIVE DATE.
WHEREAS,
the City Council has been presented a proposed Tax Abatement Agreement by
and between the City of Coppell, Texas, and Panasonic Corporation of North America, a
Delaware corporation, a copy of which is attached hereto and incorporated herein by reference; and
WHEREAS,
upon full review and consideration of the Agreement, and all matters related
thereto, the City Council is of the opinion and finds that the terms and conditions thereof should be
approved, and that the Mayor should be authorized to execute the Agreement on behalf of the City
of Coppell, Texas;
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF COPPELL, TEXAS, THAT
:
SECTION 1.
The Agreement attached hereto having been reviewed by the City Council of
the City of Coppell, Texas, and found to be acceptable and in the best interest of the City and its
citizens, be, and the same is hereby, in all things approved, and the Mayor is hereby authorized to
execute the Agreement on behalf of the City of Coppell, Texas.
SECTION 2.
The Council finds that the tangible personal property to be added to the
improvements on the Land described in the Agreement will enhance the economic vitality of the
community through a combination of new capital investment, increased sales tax revenues, and
the creation of additional job opportunities.
SECTION 3.
The tax abatement to be granted by the Agreement will not include
inventory and supplies.
SECTION 4.
The improvements proposed for the Premises will accomplish the tax
abatement guidelines of the City of Coppell, Texas.
SECTION 5.
The City Manager delivered to the presiding officer of the governing body
of each taxing unit in which the property subject to the Agreement is located, a written notice
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SECTION 5. The City Manager delivered to the presiding officer of the governing body
of each taxing unit in which the property subject to the Agreement is located, a written notice
that the City of Coppell, Texas, intends to enter into the Agreement. The notice given by the
City Manager included a copy of the Agreement approved by this Resolution.
SECTION 6. This Resolution and the Tax Abatement Agreement are hereby approved
by the affirmative vote of the majority of the members of the City Council of the City of
Coppell,Texas, at a regularly scheduled meeting of the City Council.
SECTION 7. This Resolution shall become effective immediately from and after its
passage.
DULY RESOLVED AND ADOPTED by the City Council of the City of Coppell, Texas,
on this the 01V day of ,2015.
CIT OF •PPELL, t.
' N S LBO IT,MAYOR
ATTEST:
i,
STEL PETT I OS,CITY r RETARY
APPROVED e TO FORM:
%il/ mil. ,, . .
CITY ATTO'
/ 2
Exhibit “A”
(copy of Tax Abatement Agreement to be attached)
3
STATE OF TEXAS §
§ TAX ABATEMENT AGREEMENT
COUNTY OF DALLAS §
This Tax Abatement Agreement (the "Agreement") is entered into by and between the
City of Coppell, Texas ("City"), and Panasonic Corporation of North America, a Delaware
corporation ("Company") (each a "Party" and collectively the "Parties"), acting by and through
their authorized representatives.
WITNESSETH:
WHEREAS,the City Council of the City of Coppell, Texas (the "City Council"), passed
an Ordinance (the "Ordinance") establishing Tax Abatement Reinvestment Zone No. 89 (the
"Zone"), for the real property described in Exhibit "A" (the "Land"), for commercial/industrial
tax abatement, as authorized by the Property Redevelopment and Tax Abatement Act, Chapter
312 of the Texas Tax Code, as amended (the "Tax Code"); and
WHEREAS, the City has adopted guidelines for tax abatement (the "Tax Abatement
Guidelines"); and
WHEREAS, the Tax Abatement Guidelines contain appropriate guidelines and criteria
governing tax abatement agreements to be entered into by the City as contemplated by the Tax
Code; and
WHEREAS, the City has adopted a resolution stating that it elects to be eligible to
participate in tax abatement; and
WHEREAS, in order to maintain and enhance the commercial and industrial economic
and employment base of the Coppell area, it is in the best interests of the taxpayers for City to
enter into this Agreement in accordance with said Ordinance, the Tax Abatement Guidelines and
the Tax Code; and
WHEREAS, Company has or intends to enter into a lease of approximately 134,924
rentable square feet of manufacturing and distribution space in a building located at 330 S. Royal
Lane, Coppell, Texas (the "Leased Premises"), for a period of at least five (5) years (the
"Lease"), and intends to locate certain Tangible Personal Property (hereinafter defined) at the
Leased Premises; and
WHEREAS, Company's development efforts described herein will create permanent
new jobs in the City; and
WHEREAS, the City Council finds that the contemplated use of the Leased Premises
(hereinafter defined), set forth in this Agreement, and the other terms hereof are consistent with
encouraging development of the Zone in accordance with the purposes for its creation and/or in
Page 1 Tax Abatement Agreement
City of Coppell and Panasonic Corporation of North America(TM 72317)
compliance with the Tax Abatement Guidelines, the Ordinance adopted by City, the Tax Code
and all other applicable laws; and
WHEREAS, the City Council finds that the Leased Premises sought are feasible and
practicable and would be of benefit to the Zone and to City after expiration of this Agreement;
and
WHEREAS, a copy of this Agreement has been furnished, in the manner prescribed by
the Tax Code, to the presiding officers of the governing bodies of each of the taxing units in
which the Leased Premises is located;
NOW, THEREFORE, in consideration of the mutual benefits and promises contained
herein and for other good and valuable consideration, the adequacy and receipt of which is
hereby acknowledged, including the expansion of primary employment, the attraction of major
investment in the Zone, which contributes to the economic development of Coppell and the
enhancement of the tax base in the City,the Parties agree as follows:
Article I
Definitions
Wherever used in this Agreement, the following terms shall have the meanings ascribed
to them:
"Bankruptcy or Insolvency" shall mean the dissolution or termination of a Company's
existence as a going business, insolvency, appointment of receiver for any part of a Company's
property and such appointment is not terminated within ninety (90) days after such appointment
is initially made, any general assignment for the benefit of creditors, or the commencement of
any proceeding under any bankruptcy or insolvency laws by or against such Company, and such
proceeding is not dismissed within ninety (90) days after the filing thereof; provided, however,
"Bankruptcy or Insolvency" shall not include an event that does not affect the Company's ability
to continue to make the Required Use of the Leased Premises and otherwise to meet its
obligations under this Agreement.
"City" shall mean the City of Coppell, Texas.
"Company" shall mean Panasonic Corporation of North America, a Delaware
corporation.
"Effective Date" shall mean the last date of execution of this Agreement.
"Expiration Date" shall mean March 1 of the calendar year following the calendar year in
which the fifth(5th) anniversary date of the First Year of Abatement shall occur.
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City of Coppell and Panasonic Corporation of North America(TM 72317)
"First Year of Abatement" shall mean the calendar year commencing on January 1 next
succeeding the date of issuance of a certificate of occupancy for Company's occupancy of the
Leased Premises.
"Force Majeure" shall mean any contingency or cause beyond the reasonable control of a
Party including, without limitation, acts of God or the public enemy, war, riot, civil commotion,
insurrection, adverse weather, government or de facto governmental action (unless caused by
acts or omissions of such Party), fires, explosions or floods, strikes, slowdowns, work stoppages,
epidemics or quarantine restrictions.
"Freeport Goods" shall have the same meaning as assigned by Section 11.251 of the Tax
Code and Article VIII, Section 1-j of the Texas Constitution. Freeport Goods does not include
"Goods in Transit" as defined by Tax Code, Section 11.253.
"Goods in Transit" shall have the same meaning assigned by Tax Code, Section 11.253.
"Land"means the real property described in Exhibit"A".
"Lease" shall mean the lease of the Leased Premises for a period of at least five(5) years.
"Lease Inception Date" shall mean the date the term of the Lease commences but not
later than December 31, 2015.
"Leased Premises" shall mean approximately 134,924 rentable square feet of
manufacturing and distribution space in a building located at 330 S.Royal Lane, Coppell, Texas.
"Related Agreement" shall mean any agreement, other than this Agreement, by and
between City and Company, its parent company, and any affiliated or related entity controlled or
owned by Company, or its parent company.
"Required Use" shall mean the continuous occupancy of the Leased Premises and the
distribution and manufacture of Company products thereat.
"Tangible Personal Property" shall mean furniture, fixtures and equipment owned or
leased by the Company and located at the Leased Premises, subsequent to the execution of this
Agreement. Tangible Personal Property shall not include inventory, Freeport Goods or Goods in
Transit located at the Leased Premises.
"Taxable Value" means the appraised value as certified by the Appraisal District as of
January 1 of a given year.
Article II
General Provisions
Page 3 Tax Abatement Agreement
City of Coppell and Panasonic Corporation of North America(TM 72317)
2.1 Company has or intends to enter into the Lease of the Leased Premises, which
Leased Premises is located within the city limits of City and within the Zone. Company intends
to locate and maintain Tangible Personal Property at the Leased Premises following the
Company's occupancy thereof.
2.2 The Leased Premises are not in an improvement project financed by tax increment
bonds.
2.3 This Agreement is entered into subject to the rights of the holders of outstanding
bonds of the City.
2.4 The Leased Premises are not owned or leased by any member of the Coppell City
Council or any member of the Coppell Planning and Zoning Commission.
2.5 Company shall, before May 1 of each calendar year that the Agreement is in
effect, certify in writing to City that it is in compliance with each term of the Agreement.
2.6 The Leased Premises shall, at all times during the term of this Agreement, be used
in the manner (i) that is consistent with City's Comprehensive Zoning Ordinance, as amended,
and (ii)that, during the period taxes are abated hereunder, is consistent with the general purposes
of encouraging development or redevelopment within the Zone.
Article III
Tax Abatement Authorized
3.1 This Agreement is authorized by the Tax Code and in accordance with the City
Tax Abatement Guidelines, and approved by resolution of the City Council.
3.2 Subject to the terms and conditions of this Agreement, and provided the Taxable
Value for the Tangible Personal Property is at least One Million Dollars ($1,000,000.00) as of
January 1 of the First Year of Abatement and as of January 1 of each year thereafter that this
Agreement is in effect, City hereby grants Company an abatement of seventy-five percent (75%)
of the Taxable Value of the Tangible Personal Property for a period of five (5)consecutive years,
beginning with the First Year of Abatement. The actual percentage of Taxable Value of the
Tangible Personal Property subject to abatement for each year this Agreement is in effect will
apply only to the Tangible Personal Property located at the Leased Premises subsequent to the
execution of this Agreement. The failure of the Tangible Personal Property to have a Taxable
Value of at least One Million Dollars ($1,000,000.00) as of January 1 of any given Tax Year
shall not be an event of default subject to termination and repayment of the abated taxes pursuant
to Article V hereof, but shall result in the forfeiture of the tax abatement for the Tangible
Personal Property for such Tax Year.
3.3 The period of tax abatement herein authorized shall be for a period of five (5)
consecutive years.
Page 4 Tax Abatement Agreement
City of Coppell and Panasonic Corporation of North America(TM 72317)
3.4 During the period of tax abatement herein authorized, Company shall be subject
to all taxation not abated, including but not limited to, sales tax and ad valorem taxation, if any,
with respect to the Leased Premises, inventory, and supplies.
3.5 Company agrees, subject to events of Force Majeure, to continuously lease and
occupy the Leased Premises for a period of at least five (5) consecutive years commencing on
the Lease Inception Date, or such later date that occupancy commences, but not later than
December 31, 2015, and concluding on the Expiration Date.
3.6 During the term of this Agreement following the Lease Inception Date, and
continuing thereafter until the Expiration Date, the Leased Premises shall not be used for any
purpose other than the Required Use and the operation and occupancy of the Leased Premises in
conformance with the Required Use shall not cease for more than thirty (30) days, except in
connection with and to the extent of an event of Force Majeure.
3.7 The term of this Agreement shall begin on the Effective Date and shall continue
until the Expiration Date, unless sooner terminated as provided herein.
Article IV
Leased Premises
4.1 Company intends to enter into the Lease and to locate Tangible Personal Property
at the Leased Premises. Nothing in this Agreement shall obligate Company to enter into the
Lease or to locate Tangible Personal Property at the Leased Premises, but said actions are
conditions precedent to tax abatement for Company pursuant to this Agreement.
4.2 As conditions precedent to the initiation of the tax abatement pursuant to this
Agreement (i) Company agrees to enter into the Lease on or before December 31, 2015; and
(ii)Company agrees to occupy the Leased Premises on or before December 31, 2015.
4.3 Company agrees to maintain the Leased Premises during the term of this
Agreement in accordance with all applicable state and local laws, codes, and regulations.
4.4 City, its agents and employees shall have the right of access to the Leased
Premises at reasonable times and with reasonable written notice to Company, and in accordance
with visitor access and security policies of the Company, in order to insure that Company is in
compliance with the terms and conditions of this Agreement.
Article V
Default: Recapture of Tax Revenue
5.1 In the event Company: (i) fails to occupy the Leased Premises in accordance with
this Agreement or in accordance with applicable State or local laws, codes or regulations; (ii)has
delinquent ad valorem or sales taxes owed to City (provided Company retains its right to timely
and properly protest such taxes or assessment); (iii) suffers an event of "Bankruptcy or
Page 5 Tax Abatement Agreement
City of Coppell and Panasonic Corporation of North America(TM 72317)
Insolvency"; or (iv) breaches any of the terms and conditions of this Agreement, or Related
Agreement, which is not otherwise cured within the applicable cure period, then Company, after
the expiration of the notice and cure periods described below, shall be in default of this
Agreement. As liquidated damages in the event of such default, Company shall, within forty-
five (45) days after termination, pay to City all taxes which otherwise would have been paid by
Company to City without benefit of a tax abatement for the property the subject of this
Agreement at the statutory rate for delinquent taxes as determined by Section 33.01 of the Tax
Code, as amended, but without penalty. The Parties acknowledge that actual damages in the
event of default termination would be speculative and difficult to determine. The Parties further
agree that any abated tax, including interest, as a result of this Agreement, shall be recoverable
against the Company, its successors and assigns and shall constitute a tax lien against the
Tangible Personal Property, and shall become due, owing and shall be paid to City within forty-
five(45) days after notice of termination.
5.2 Upon breach by Company of any of the obligations under this Agreement, City
shall notify Company in writing, which shall have sixty (60) days from receipt of the written
notice in which to cure any such default. If the default cannot reasonably be cured within such
sixty (60) day period, and Company has diligently pursued such remedies as shall be reasonably
necessary to cure such default, then City may extend the period in which the default must be
cured.
5.3 If Company fails to cure the default within the time provided as specified above
or, as such time period may be extended, then City, at its sole option, shall have the right to
terminate this Agreement by providing written notice to Company.
5.4 Upon termination of this Agreement by City, all tax abated as a result of this
Agreement, shall become a debt to City as liquidated damages, and shall become due and
payable not later than forty-five (45) days after a written notice of termination is provided. City
shall have all remedies for the collection of the abated tax provided generally in the Tax Code for
the collection of delinquent property tax. City, at its sole discretion, has the option to provide a
repayment schedule. The computation of the abated tax for the purposes of the Agreement shall
be based upon the full Taxable Value of the Tangible Personal Property without tax abatement
for the years in which tax abatement hereunder was received by Company, as determined by the
Appraisal District, multiplied by the tax rate of the years in question, as calculated by the City
Tax Assessor-Collector. The liquidated damages shall incur penalties as provided for delinquent
taxes and shall commence to accrue after expiration of the forty-five (45) day payment period.
Article VI
Annual Application for Tax Exemption
It shall be the responsibility of Company, pursuant to the Tax Code, to file an annual
exemption application form for the Tangible Personal Property with the Chief Appraiser for each
Appraisal District (or its successor) in which the eligible taxable property has situs. A copy of
the respective exemption application shall be submitted to City upon written request.
Page 6 Tax Abatement Agreement
City of Coppell and Panasonic Corporation of North America(TM 72317)
Article VII
Annual Rendition
Company shall annually render the value of the Tangible Personal Property to the
Appraisal District, and shall provide a copy of the same to City upon written request.
Article VIII
Miscellaneous
8.1 Notice. Any notice required or permitted to be delivered hereunder shall be
deemed received three (3) days thereafter sent by United States Mail, postage prepaid, certified
mail, return receipt requested, addressed to the Party at the address set forth below or on the day
actually received if sent by courier or otherwise hand delivered:
If intended for City, to: With a copy to:
Attn: City Manager Peter G. Smith
City of Coppell, Texas Nichols, Jackson, Dillard, Hager& Smith, L.L.P.
P. O. Box 478 1800 Ross Tower
Coppell,Texas 75019 500 N. Akard
Dallas, Texas 75201
If intended for Company,to: With a copy to:
Attn: Tomohiro Ohi Attn: Damien Atkins
Director of Procurement and General Counsel
Real Estate and Facilities Legal Department
Panasonic Corporation of North America Panasonic Corporation of North America
Two Riverfront Plaza, 9th Floor Two Riverfront Plaza, 12th Floor
Newark,NJ 07102-5490 Newark,NJ 07102-5490
8.2 Authorization. This Agreement was authorized by resolution of the City Council
approved by its Council meeting authorizing the Mayor to execute this Agreement on behalf of
City.
8.3 Severability. In the event any section, subsection, paragraph, sentence, phrase or
word herein is held invalid, illegal or unconstitutional, the balance of this Agreement shall stand,
shall be enforceable and shall be read as if the Parties intended at all times to delete said invalid
section, subsection, paragraph, sentence, phrase or word.
8.4 Governing Law. This Agreement shall be governed by the laws of the State of
Texas without regard to any conflict of law rules. Exclusive venue for any action under this
Agreement shall be the State District Court of Dallas County, Texas. The Parties agree to submit
to the personal and subject matter jurisdiction of said court.
Page 7 Tax Abatement Agreement
City of Coppell and Panasonic Corporation of North America(TM 72317)
8.5 Counterparts. This Agreement may be executed in any number of counterparts,
each of which shall be deemed an original and constitute one and the same instrument.
8.6 Entire Agreement. This Agreement embodies the complete agreement of the
Parties hereto, superseding all oral or written previous and contemporary agreements between
the Parties and relating to the matters in this Agreement, and except as otherwise provided herein
cannot be modified without written agreement of the Parties to be attached to and made a part of
this Agreement.
8.7 Recitals. The determinations recited and declared in the preambles to this
Agreement are hereby incorporated herein as part of this Agreement.
8.8 Exhibits. All exhibits to this Agreement are incorporated herein by reference for
all purposes wherever reference is made to the same.
8.9 Assignment. This Agreement shall be binding on and inure to the benefit of the
parties to it and their respective heirs, executors, administrators, legal representatives, successors,
and permitted assigns. This Agreement may not be assigned by the Company without the prior
written consent of the City Manager.
8.10 Employment of Undocumented Workers. During the term of this Agreement, the
Company agrees not to knowingly employ any undocumented workers and, if convicted of a
violation under 8 U.S.C. Section 1324a(f), Company shall repay the taxes abated herein, and any
other funds received by Company from the City as of the date of such violation within one
hundred twenty (120) days after the date the Company is notified by City of such violation, plus
interest at the rate of four percent (4%) compounded annually from the date of violation until
paid. Company is not liable for a violation of this section in relation to any workers employed
by a subsidiary, affiliate, or franchisee of Company or by a person with whom the Company
contracts.
8.11 Right of Offset. City may at its option, offset any amounts due and payable under
this Agreement against any debt (including taxes) lawfully due to City from the Company,
regardless of whether the amount due arises pursuant to the terms of this Agreement, a Related
Agreement or otherwise, and regardless of whether or not the debt due City has been reduced to
judgment by a court.
8.12 Conditions Precedent. This Agreement is subject to and conditioned upon the
following conditions which are conditions precedent to the obligations of the Parties:
(i)Company entering into the Lease on or before December 31, 2015; and (ii) Company
occupying the Leased Premises on or before December 31, 2015.
[Signature Page to Follow]
Page 8 Tax Abatement Agreement
City of Coppell and Panasonic Corporation of North America(TM 72317)
`1k
EXECUTED in duplicate originals thed5 day i f /,�,,A , 2015.
CITY OF C J PPEL ,TEXAS /
12b
By: 1444A`i 1
K:ren Se .o Hunt, Ma or
Attest:
By:
Christel Pettino , City Secret y
Agreed as ' irm:
// /,-A/
By: 4
City Attorney
EXECUTED in duplicate originals the IS day of d c..-1, b , 2015.
PANASONIC CORPORATION OF NORTH AMERICA
By: 1dri,
Tomohiro Ohi
Director of Procurement and
Real Estate and Facilities
Page 9 Tax Abatement Agreement
City of Coppell and Panasonic Corporation of North America(TM 72317)
Exu1BIT"A"
Legal Description of Land
Block A, Lot 1C-R, of Amberpoint Business Park of Coppell (12.691 acres)
Page 10 Tax Abatement Agreement
City of Coppell and Panasonic Corporation of North America(TM 72317)