SB3300 • 2026

RELATING TO PROCEDURES FOR TAX APPEALS.

Taxes

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Sponsor: KOUCHI (Introduced by request of another party)
Last action: 2026-02-19
Official status: Report adopted; Passed Second Reading, as amended (SD 1) and referred to WAM.
Effective date: Not listed

Plain English Breakdown

Using official source text because the generated explanation was unavailable or could not be confirmed against the official bill text.

RELATING TO PROCEDURES FOR TAX APPEALS.

What This Bill Does

RELATING TO PROCEDURES FOR TAX APPEALS.
Taxation; Tax Appeals; Payments Under Protest Requires a tax to be paid before the courts may entertain a second appeal on the merits of the dispute.
Requires a taxpayer who partially prevailed during the taxpayer's first appeal to pay the amount determined to be due in that first appeal, rather than the entire assessment, in order to make a subsequent appeal.
Clarifies that a taxpayer who does not appeal the decision of the body reviewing the initial tax assessment by the Department of Taxation is required to pay the tax as determined by the Taxation Board of Review or Tax Appeal Court or the tax assessment by the Department of Taxation if left unmodified and unamended by the Board or Court.

Limits and Unknowns

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Amendments

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SD1

Hawaii published version SD1

Plain English: SB3300 SD1 THE SENATE S.B.

SB3300 SD1 THE SENATE S.B.
NO.
3300 THIRTY-THIRD LEGISLATURE, 2026 S.D.
1 STATE OF HAWAII A BILL FOR AN ACT relating to procedures for tax appeals .

Bill History

2026-02-19 S
Report adopted; Passed Second Reading, as amended (SD 1) and referred to WAM.
2026-02-19 S
Reported from JDC (Stand. Com. Rep. No. 2442) with recommendation of passage on Second Reading, as amended (SD 1) and referral to WAM.
2026-02-10 S
The committee(s) on JDC recommend(s) that the measure be PASSED, WITH AMENDMENTS. The votes in JDC were as follows: 4 Aye(s): Senator(s) Rhoads, Gabbard, Chang, San Buenaventura; Aye(s) with reservations: none ; 1 No(es): Senator(s) Awa; and 0 Excused: none.
2026-02-05 S
The committee(s) on JDC has scheduled a public hearing on 02-10-26 9:15AM; Conference Room 016 & Videoconference.
2026-02-02 S
Referred to JDC, WAM.
2026-01-30 S
Passed First Reading.
2026-01-30 S
Introduced.

Official Summary Text

RELATING TO PROCEDURES FOR TAX APPEALS.
Taxation; Tax Appeals; Payments Under Protest
Requires a tax to be paid before the courts may entertain a second appeal on the merits of the dispute. Requires a taxpayer who partially prevailed during the taxpayer's first appeal to pay the amount determined to be due in that first appeal, rather than the entire assessment, in order to make a subsequent appeal. Clarifies that a taxpayer who does not appeal the decision of the body reviewing the initial tax assessment by the Department of Taxation is required to pay the tax as determined by the Taxation Board of Review or Tax Appeal Court or the tax assessment by the Department of Taxation if left unmodified and unamended by the Board or Court. (SD1)

Current Bill Text

Read the full stored bill text

SB3300

THE SENATE

S.B. NO.

3300

THIRTY-THIRD LEGISLATURE, 2026

STATE OF HAWAII

A BILL FOR AN ACT

relating
to procedures for tax appeals
.

BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF HAWAII:

����
SECTION 1.
�
The
legislature finds that in the recent case
In re:
�
Tax Appeal of PM & AM Research, Inc. v.
State
, CAAP‑25‑0000525 (Haw. App. Sept. 17, 2025), a taxpayer
attempted to appeal a tax assessment by the department of taxation to the
Hawaii tax appeal court.
�
Due to a
procedural technicality, the court dismissed the appeal.
�
On appeal to the intermediate court of
appeals, the court observed that the taxpayer had not paid the assessed tax, as
required by section 235-114, Hawaii Revised Statutes, and dismissed the appeal
on that basis.
�
Thus, the taxpayer was
denied any substantive review of the assessment.

����
Accordingly, the purpose of this Act is to
clarify that:

����
(1)
�
A
tax shall be paid before the courts may entertain a second appeal on the merits
of the dispute; and

����
(2)
�
A
taxpayer who partially prevailed during the taxpayer's first appeal shall pay the
amount determined to be due in that first appeal, rather than the entire
assessment, in order to make a subsequent appeal.

����
SECTION
2
.
�
Section 235-114, Hawaii Revised Statutes, is
amended by amending subsection (a) to read as follows:

����
"
(a)
�
Any person aggrieved by any assessment of the
tax or liability imposed by this chapter may appeal from the assessment in the
manner and within the time hereinafter set forth.
�
Appeal may be made either to the taxation
board of review or to the tax appeal court.
�

The first appeal to either the taxation board of review or to the tax
appeal court may be made without payment of the tax assessed.
�
Either the taxpayer or the assessor may
appeal to the tax appeal court from a decision by the board or to the intermediate
appellate court from a decision by the tax appeal court; provided that if the
decision
on the merits
by the board or the tax appeal court is appealed
by the taxpayer, [
or the decision by the board in favor of the department is
not appealed,
] the taxpayer shall pay the tax [
assessed
]
, as
determined by the board or the tax appeal court,
plus interest as provided
in section 231-39(b)(4)."

����
SECTION 3.
�

This Act does not affect rights and duties that matured, penalties that
were incurred, and proceedings that were begun before its effective date.

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SECTION 4.
�

Statutory material to be repealed is bracketed and stricken.
�
New statutory material is underscored.

����
SECTION 5.
�

This Act shall take effect upon its approval.

INTRODUCED BY:

_____________________________

Report Title:

Taxation;
Tax Appeals; Payments Under Protest

Description:

Requires
a tax to be paid before the courts may entertain a second appeal on the merits
of the dispute.
�
Requires a taxpayer who
partially prevailed during the taxpayer's first appeal to pay the amount
determined to be due in that first appeal, rather than the entire assessment,
in order to make a subsequent appeal.

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not legislation or evidence of legislative intent.