[WSBAPT] Washington estate tax question

[Karin Treadwell]

Out of state couple own a commercial property in Washington via a Washington LLC.  They also own two Washington residential properties as rentals, and for liability purposes would like to transfer these to Washington LLCs.

Assuming they have established domicile out of state, wouldn't the value of the business interests (whether held by the couple personally or their RLT) be considered an intangible asset and thus out of state property for Washington estate tax purposes?

The DOR website emphasizes that whether an ownership interest is determined to be an intangible or tangible asset is based on whether it is operating for a "true business purpose."

Any feedback on how DOR is defining a true business purpose?  Operating a commercial building?  What about putting rental homes into an LLC for liability protection?

Karin
Karin S. Treadwell
Sayre Law Offices, PLLC
1417 31st Ave S
Seattle WA  98144-3909

phone 206-625-0092
fax 206-625-9040

Please Note that We Have Moved

We have moved our Seattle office to Mount Baker Ridge (a small commercial community just above the I-90 tunnel).

Our new address is 1417 31st Avenue South, Seattle WA 98144

All other contact information will remain the same

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