[WSBARP] Excise tax exemption LLC to member of LLC Member

Stuart Ainsley stuart at glgmail.com
Thu Aug 19 15:04:58 PDT 2021


Could you rely on the exemption for a transaction not taxable under the internal revenue code?

Stuart M. Ainsley
Attorney
GOURLEY LAW GROUP
THE EXCHANGE CONNECTION
SNOHOMISH ESCROW
P.O. Box 1091
Snohomish, WA 98291
PH:  (360) 568-5065 (800) 291-8401
Fax: (360) 568-8092

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From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Nestor Gorfinkel
Sent: Thursday, August 19, 2021 2:57 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Excise tax exemption LLC to member of LLC Member

An LLC owns a house where its only member is an LLC, and the transfer is going to individual members of the "LLC member".

Is this exempt under WAC 458-61A-211(2)? I am looking to see where this scenario falls (b) or (d) fall short.
None of the exemption appear to apply even though the end result is no change in beneficial interest.

Nestor Gorfinkel, Attorney at Law
Licensed in Florida & Washington State
Florida Civil-Law (International) Notary

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