A California Court of Appeal held that San Francisco may not impose a documentary transfer tax on the value of an existing 41-year leasehold interest upon the sale of the underlying property because the leasehold interest does not constitute “realty sold”. The taxpayer owned a commercial building and agreed to lease the ground floor to

By Dmitrii Gabrielov and Tim Gustafson

The New York State Supreme Court, Appellate Division, affirmed the New York City Tax Appeals Tribunal’s (Tribunal) determination that certain real estate transactions were subject to the New York City Real Property Transfer Tax (RPTT) under the step transaction doctrine.

The taxpayer and a nonparty owned, respectively, 45% and