Laws, Regulations & Annotations
Property Taxes Law Guide – Revision 2013
Property Tax Annotations
220.0000 CHANGE IN OWNERSHIP
220.0003 Affiliated Group Transfer. Under Revenue and Taxation Code section 64(b), any transfer of real property among members of an affiliated group is not a change in ownership. An "affiliated group" is one or more chains of corporations connected through stock ownership with a common parent corporation if: (1) 100 percent of the voting stock (exclusive of that owned by directors) of each of the corporations, except the parent corporation, is owned by one or more of the other corporations; and (2) the common parent corporation owns, directly, 100 percent of the voting stock (exclusive of that owned by directors) of at least one of the other corporations. Thus, an affiliated group requires the common ownership to be among corporations. A transfer to a limited liability company is not a transfer among members of an affiliated group so the exclusion under section 64(b) is inapplicable. C 4/20/2012.