[WSBAPT] Excise tax exemption question

[Eric Nelsen]

I would suggest checking WAC 458-61A-212<https://apps.leg.wa.gov/wac/default.aspx?cite=458-61A-212>, transfers where gain not recognized under IRC. See especially 2(c) and (4). I have no idea whether it would work, but it's the only thing I can think of for this context.

Sincerely,

Eric

Eric C. Nelsen
Sayre Law Offices, PLLC
1417 31st Ave South
Seattle WA 98144-3909
206-625-0092
eric at sayrelawoffices.com<mailto:eric at sayrelawoffices.com>

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From: wsbapt-bounces at lists.wsbarppt.com <wsbapt-bounces at lists.wsbarppt.com> On Behalf Of Rich McEntee
Sent: Monday, November 16, 2020 9:03 AM
To: wsbapt at lists.wsbarppt.com
Subject: [WSBAPT] Excise tax exemption question

Good morning

This is a cross post from another listserve. Hopefully not too many already received it.

I am looking for a bit of guidance.

Client (an individual) is 100% owner of ABC corporation. Client is also owns 50% interest in XYZ corporation.

XYZ corporation owns real estate. XYZ corporation would like to sell/transfer its entire interest in real estate to ABC corporation. ABC corporation will pay fair market value to XYZ as part of the transfer. Is there a partial excise tax exemption available due to the fact that the client has an ownership position in each entity? The client is essentially buying 50% of the real estate from himself.

Thank you, in advance for your guidance.

Rich

RICH McENTEE
McENTEE LAW OFFICE
3800 Bridgeport Way W, Ste A411<x-apple-data-detectors://1/1>
University Place, WA 98466<x-apple-data-detectors://1/1>
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