The taxable status of a property in a Second Class County is fixed as of the date designated by law as assessment day, not the date of a change in ownership, the Commonwealth Court held in Global Links v. Keystone Oaks School District, __ A.3d __ (No. 1511 C.D. 2014, filed May 8, 2015). Global Links, a purely public charity, purchased the subject property in Allegheny County on July 3, 2012. It sought an exemption from real estate taxes effective as of the purchase date. The County Board of Property Assessment Appeals and Review denied the request because, under the so-called “Tax Assessment Day Rule,” Global Links’ exemption did not become effective until the next designated tax assessment day for the County, which was January 1, 2013. Global Links appealed to the trial court, arguing that the Tax Assessment Day Rule was eliminated in Allegheny County by 1978 amendments to the General County Assessment Law. The trial court disagreed and affirmed the Board.
On appeal to the Commonwealth Court, Global Links again argued that the Tax Assessment Day Rule in Allegheny County was abrogated by Section 505(b) of the General County Assessment Law, which expressly allowed for mid-year tax roll revisions when property is exchanged between taxed and tax-exempt entities. 72 P.S. §5020-505(b). The Commonwealth Court rejected Global Links’ argument. Writing for the unanimous panel, President Judge Pellegrini explained that the General County Assessment Law applies to second class counties except where it is inconsistent with the Second Class County Assessment Law. Section 10 of the latter law, 72 P.S. §5452.10, which deals with the revision of assessments, contains no provision allowing for mid-year revisions like those authorized by Section 505(b). Thus, the Court held that because Section 10 of the Second Class County Assessment Law is inconsistent with Section 505(b) of the General County Assessment Law, the latter provision does not apply to counties of the second class and the Tax Assessment Day Rule has not been abrogated in Allegheny County.