The Florida Department of Revenue recently acknowledged that a transfer of unencumbered real property between two commonly controlled limited liability companies is not subject to Florida documentary stamp taxes. This ruling was a reasonable extension of the Florida Supreme Court case of Crescent Miami Center LLC that similarly found no taxes due on a transfer to an LLC by a limited partner of a partnership that wholly owed the LLC. Florida Technical Assistance Advisement 05(B)4-004, 06/23/2005.
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