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California holds documentary transfer tax can apply to transfers of interests in legal entities that own real estate

On June 29, 2017, the California Supreme Court held that the documentary transfer tax may apply to transfers of interests in legal entities that own real estate. Specifically, the court held that the documentary transfer tax may be imposed when a transfer of a legal entity results in a change in ownership of real property within the meaning of Cal. Rev. & Tax. Code Sec. 64(c) or (d).