Passing a Washington, DC, office building between two related entities was a taxable event, the District of Columbia Court of Appeals ruled Thursday, upholding a $5.9 million transfer tax bill.
The court rejected the entities’ argument that the transfer resulted from a non-taxable conversion rather than a merger. “All of the contemporaneous documents indicate that both the LLC and the Partnership existed before the transaction and then merged, with the LLC being the entity that survived the merger,” Judge Roy W. McLeese wrote for the unanimous panel.
Despite asking for supplemental briefing on the effects of the US Supreme Court’s ...