NYC Judge Applies Step Transaction Doctrine but Cancels Real Property Transfer Tax Assessment
By EsqSocial Corporation 23/10/24
A recent New York City (“NYC”) determination limited the impact of the step transaction doctrine under the New York City real property transfer tax (“RPTT”). An Administrative Law Judge (“ALJ”) held that the collapsing of a deed to a newly formed entity, followed by a transfer of an economic interest in that entity, resulted in a nontaxable transfer of a less than 50% economic interest in the entity. Matter of 105-02 Forest Hills LLC., et al., TAT (H) 20-18 (RP), et al. (N.Y.C. Tax App. Trib.,...
By: Blank Rome LLP