TAKEAWAYS The California Supreme Court’s Ardmore decision concludes counties and cities are permitted to impose transfer tax on entity transfers that result in R&TC §§ 64(c) or 64(d) changes in ownership. Litigation over how to implement this taxation is a certainty. In 926 North Ardmore Avenue LLC v. County of…
(This article originally was published by Law360 on July 7, 2016.) Rarely does a subject as mundane as a documentary transfer tax become worthy of its own article. However, the June 29, 2017, decision of the California Supreme Court in 926 North Ardmore Avenue LLC v. County of Los Angeles…
In 926 North Ardmore Avenue, LLC v. County of Los Angeles, the 2nd District Court of Appeal held that Proposition 13 changes in ownership prompted by transfers of legal entity interests should also be characterized as “realty sold,” resulting in the imposition of realty transfer taxes under the California Documentary…