Experience Category: Real Property Transfer Tax

Application of Florida RPTT to Tiered Partnership

Analysis and advice relating to sale of upper-tier partnership interests in GP-LP structure involving Florida real estate and the application of real estate tax to transfers of upper-tier interests where lower-tier partnership held commercial Florida real estate.

Real Property Transfer Tax Application to Pre-Distribution Plan

Discussion, advice and documentation relating to distribution of units in development where initial investors had designated individual units for distribution at completion of construction but were prevented from fully binding transfer by restrictions of plan documents.  Analysis of RPTT mere change of form of ownership rules applied to bespoke situation and best approach to documenting ultimate transfer of title.

Audit & Appeal of RPTT Rate Applied to Joint Cooperative

Audit & appeal (multi-stage through local tax tribunal) of application of bulk rate to contiguously-joined coop unit, research and presentation of administrative precedent and application of same to unusual fact pattern involving prior conjoined use followed by intervening separate use of physically connected units.
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