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

[Nestor Gorfinkel]

As it stands now, it doesn't appear on its face to be exempt from Excise tax.


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

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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 6:38 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Excise tax exemption LLC to member of LLC Member

I See your point or if we simply assign the membership interest in the Member LLC directly to the individual members.

I am not sure why there is a second layer for the LLC, and I requested that they ask their financial advisor or CPA, before I start mucking up the works.


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

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From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Athena Dickerson
Sent: Thursday, August 19, 2021 6:19 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Excise tax exemption LLC to member of LLC Member

Maybe a 2 step process, the first transfer to the member LLC using the exemption and the 2nd being a move to its members using the same exemption?  I assume the "members" of both LLC's are the same and in the same percentages.

Athena Makratzakis Dickerson
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From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto: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<mailto: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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