[WSBARP] Skipping a step in Excise Tax

[Bryce Dille]

I've wrestled with this in the past and decided its best to keep a chain of title from LLC to member and then to single person LLC although it involves an extra deed and recording fee. What you might so if other members agree is transfer that members ownership interest to the LLC now so it is now a member of the Parent LLC and then transfer to the member LLC. That way you maintain the chain of title and save a recording fee.

From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Craig Gourley
Sent: Wednesday, April 22, 2020 10:30 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Skipping a step in Excise Tax

Listmates,  I have an LLC that wishes to distribute their building to the members who are individuals.  This distribution would be exempt as mere change in form of ownership.  Each member wants to have their interest transferred to a new, single member LLC which is again exempt as another mere change in form of ownership.   Client wishes to make the transfer directly from the LLC to the member's new LLCs.  Has anyone dealt with DOR on this issue of skipping the intermediate step of going out to the individuals first?   DOR of course, will not provide me any insight into their policy without a formal request for determination and we don't have 30 days to wait.  As always,  your insight is appreciated.  Craig

Gourley Law Group
Snohomish Escrow
The Exchange Connection

1002 10th Street / PO Box 1091
Snohomish, WA 98291

360.568.5065
360.568.8092  fax
Craig at glgmail.com<mailto:Craig at glgmail.com>


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