[WSBAPT] Controlling Interest Transfer Question

[Bryce Dille]

No tax in December member only owned 25% already paid excise tax on transfer of the 50% or more

Bryce H. Dille
Dille Law, PLLC
2010 Caton Way SW Ste. 101
Olympia, WA 98502
Office: 360-350-0270
Cell: 253-579-5561

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Business Entity Creation and Management, Business, Government and Tax Law, Real Estate and Land Use, Residential, Commercial and Condominium Development Real Estate and Commercial Transactions & Closings, Including Performing Services as IRS Section 1031 Exchange Facilitator Estate Planning, including Wills and Trusts, and Probate Administration Representation Homeowners/Condominium Association Real Estate Developments Real Property Foreclosures and Forfeitures.

From: wsbapt-bounces at lists.wsbarppt.com <wsbapt-bounces at lists.wsbarppt.com> On Behalf Of Amy Allison
Sent: Monday, March 8, 2021 4:30 PM
To: WSBA Probate & Trust Listserv <wsbapt at lists.wsbarppt.com>
Subject: [WSBAPT] Controlling Interest Transfer Question

I'm reaching out to see if anyone knows whether the controlling interest transfer time period "resets" after payment of excise tax.

Scenario would be that Member owns 75% of an LLC.

Member sells 25% in January.    No excise tax due.

Member sells another 25% in July.  Excise tax is due based on the FMV of the property.

THEN Member sells her last 25% in December.    Is excise tax due again or did the payment of the tax in July reset the 3 year period?


Amy C. Allison
Anderson Hunter Law Firm, P.S.
2707 Colby Ave. #1001
Everett, WA 98201
(425) 252-5161
Direct:  (425) 303-3109
Fax: (425) 258-3345
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