The California Supreme Court, in a 6-1 decision, has held that a city or county may impose documentary transfer tax on the transfer of the ownership interests in a legal entity that owns real property located in the locality. In 926 North Ardmore Avenue, LLC v. County of Los Angeles,1 the court held that the documentary transfer tax applies to a written instrument conveying an interest in a legal entity that owns real property. This approach adopts the “change in ownership” regime for property tax purposes and applies it to the documentary transfer tax.
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