Laws, Regulations & Annotations

Property Taxes Law Guide – Revision 2018

Property Tax Annotations

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Annotation 220.0090

220.0090 Corporate Reorganization. A corporate reorganization effected by a series of stock transfers among corporations that have common owners will not result in a change in ownership of the real property of any of the corporations if each transfer either does not constitute a change in ownership or is excluded from change in ownership. For purposes of applying Revenue and Taxation Code section 64(b), if affiliation is one of multiple steps in the reorganization, then the provisions of that section are not applicable. In order to qualify for that exclusion, the corporations involved must be affiliated prior to the first step in the reorganization. Additionally, the step transaction doctrine may be applicable in analyzing such a series of transfers. C 2/14/1992.