The documentary stamp tax, sometimes called transfer tax, is assessed on the amount of the consideration paid for the transfer of any interest in real property located in Florida. First, it maintains the integrity of the three-year period during which the documentary stamp tax applies to the sale of conduit entities. Step two would not be subject to the documentary stamp tax because there is no conveyance of real estate, since S is assigning a membership interest in a limited liability company. The County Clerk collects this tax when the document transferring property is recorded. 2 Dist. Grantor trusts tax the grantor on trust income as though the grantor had retained the property instead of creating the trust. 79 Fla. B. J. The grantor either gratuitously transfers assets to such trusts or sells assets to such trusts. The second lesson is more taxpayer-favorable - that once documentary stamp taxes are paid on a transfer of interests of a conduit entity, successive transfers are not taxed. Florida documentary tax stamp rates are the same in each county, with the exception of Miami-Dade. In such case, the documentary stamp tax would not apply to the grantor’s sale of ownership interests in such public company. There is no maximum tax on these documents. Documentary stamp tax of $210 was paid on the document that transferred the real property to the LLC. 44 (Oct. 2005). When the full amount of the consideration for the execution, assignment, transfer, or conveyance is not shown in the face of such deed, instrument, document, or writing, the tax shall be at the rate of 70 cents for each $100 or fractional part thereof of the consideration therefor. 76 Fla. B. J. at 42 (May 2002). If you are using any other web browsers, this site may not appear or function as designed. Under Crescent, there was no documentary stamp tax due on steps one or three since each of these transfers is a mere book transaction where beneficial ownership of the property has not changed. Prior to July 1, 2009, sellers of unencumbered Florida real estate were able to avoid the documentary stamp tax by first transferring the real estate to a limited liability company wholly-owned by the sellers, then transferring the LLC interests to the buyer. As an initial matter, it is difficult to properly define “a transfer for purposes of estate planning,” as estate planning itself is an extremely broad concept. Conclusion The 2007 and 2009 statutory revisions described in this article create new requirements and issues for Florida practitioners that deal with the conveyance of Florida real estate. The Florida Documentary Stamp is a tax levied in Florida on documents that transfer a property interest in Florida. Under the example, one person transfers real estate to his wholly-owned LLC, and within 3 years transfers 50% of the LLC to a second person. When real property is sold, the property is typically assessed the following January 1 in part based on the recorded sales price. Center, LLC v. Florida Department of Revenue, holding that when unencumbered property is transferred from the owner to a wholly owned legal entity – such as a limited liability company or wholly owned partnership - it is not subject to the Florida documentary stamp tax. However, because the Supreme Court’s interpretation, combined with other settled law regarding the application of s. 201.02, Florida Statutes, allows for the tax-free transfer of ownership interests in real property from one owner to another through the use of artificial entities, it is the Legislature’s intent by this act to impose the documentary stamp tax when the beneficial ownership of real property is transferred to a new owner or owners by the use of techniques that apply the Supreme Court’s decision in Crescent in combination with transfers of ownership of, or distributions from, artificial entities.12. However, the transaction could alternatively be structured as follows: 1) S contributes the real estate to a wholly owned, special purpose limited liability company formed solely for the transaction, S LLC; 2) S then sells the membership interests in S LLC to P for the $5 million purchase price; 3) P then dissolves S LLC and takes title to the real estate. 2d 913 (Fla. 2005), interprets s. 201.02, Florida Statutes, in a manner that permits tax avoidance inconsistent with the intent of the Legislature at the time the statute was amended in 1990.”11. Documentary stamp tax is levied at the rate of $.70 per $100 (or portion thereof) on documents that transfer interest in Florida real property, such as warranty deeds and quit claim deeds. DOCUMENTARY STAMP TAX: Add to MyFLRules Favorites: View Chapter: 12B-4. Irrevocable grantor trusts are frequently used in estate planning to create a vehicle that holds assets that are not included in the grantor’s estate for estate tax purposes, but treated as owned by the grantor for income tax purposes. Daniel J. Glassman is an associate in the Tax Practice Group at Gunster, Yoakley & Stewart, P.A. This website is optimized for use on a PC using Microsoft Internet Explorer. Documentary stamp taxes are due on the transfer of 50% of the LLC interests to the second person. The Emergency Rule provides guidance on indirect transfers of LLC interests by providing an example of an indirect transfer and an example involving successive transfers. The Florida Documentary Stamp Tax Florida imposes a documentary stamp tax on transfers of real estate by deed at a rate of $.70 per $100 or part thereof of consideration. The Crescent decision resulted in the proliferation of transaction planning that avoided the imposition of the deed tax and caused a headache for property appraisers attempting to determine the valuation of Florida real property for ad valorem tax purposes.2 In response to the “abuse” of Crescent, the legislature amended §201.02 in 2009 to apply the Florida documentary stamp tax to the sale of ownership interests in an entity that owns Florida real property where such real property was conveyed to the entity within three years of sale.3 In addition, in 2007, the legislature enacted §193.1556 to require notice to property appraisers upon the change of control of certain entities owning Florida real estate. Lessons. CMC recorded the deed and paid documentary stamp tax on the full value of the conveyance. In addition to the payment of any increase in taxes during such 10-year period, the property owner would be required to pay interest at a 15 percent annual rate on such increase in taxes and a penalty of 50 percent of such increase in taxes.22. © 2021 The Florida Bar. Therefore, the payment of the deed tax and the change of control disclosure should be addressed in due diligence checklists and in purchase and sale agreements, so that these items do not slip through the cracks when Florida real property is directly or indirectly conveyed as part of a transaction. Deeds 2. The rate is equal to 70 cents per $100 of the deed's consideration. The statute explicitly excludes the following transfers: Where the transfer of LLC interests is 3 years or more from the date that the real estate was contributed to the LLC; Where the transfer of conduit entity interests is a gift; Where the conduit entity is publicly traded; Where the conduit entity is transferred, as part of the estate planning of the grantor, to an irrevocable grantor trust. Under the grantor trust provisions, a grantor is taxed on trust income if the grantor retains a reversionary interest whose value is initially greater than five percent of the value of the trust or specified rights to control beneficial enjoyment of the corpus or income or if the grantor retains or vests in a nonadverse party certain administrative powers. The Florida documentary stamp tax statute provides in pertinent part: On deeds, instruments, or writings whereby any lands, tenements, or other real property, or any interest therein, shall be granted, assigned, transferred, or otherwise conveyed to, or vested in, the purchaser or any other person by his or her direction, on each $100 of the consideration therefor the tax shall be 70 cents. The examples provided by Emergency Rule 12B11-17 illustrate how the Florida DOR intends to apply the documentary stamp tax to indirect and successive transfers of conduit entities. However, if the second person later sells her LLC interests to a third person, no documentary stamp taxes are due on the transfer to the third person, since documentary stamp taxes were paid on the transfer to the second person. The legislature addressed its stated concerns by amending §201.02 to confirm the essence of the Florida Supreme Court’s opinion in Crescent that a conveyance of unencumbered real property to an entity is not subject to documentary stamp tax. For over half a century, Florida tax practitioners have struggled to answer a relatively simple question. The conveyance or merger would start the three-year clock running. The Legislature expressly rejects any application of the court’s interpretation where the facts are not comparable to the facts in Crescent. Thus, a potential buyer would be hesitant to acquire interests in an entity that was funded with real estate and has been operating for more than three years. May 15, 1998), and as finally confirmed by the Florida Supreme Court in Crescent Miami Center LLC in 2005, transfers of Florida real property from owners to wholly-owned entities are not subject to Florida documentary stamp taxes, at least when the property is unencumbered. While the legislature voiced its endorsement of the opinion issued by the Third District Court of Appeal in Crescent, which the legislature stated interpreted §201.02 in a manner that prevented tax avoidance, it also stated that it does not intend to overturn the Florida Supreme Court’s decision in Crescent with respect to the conveyance of unencumbered Florida real property to artificial entities. Estate planners often refer to these irrevocable grantor trusts as “intentionally defective grantor trusts.”. The Crescent Case and Its Aftermath In Crescent, the Florida Supreme Court addressed the application of the Florida documentary tax to the conveyance of a commercial building located in downtown Miami from a limited partnership to a wholly owned, second-tier subsidiary limited liability company called Crescent Miami Center, LLC (CMC). Absent any documentary stamp tax planning, the sale of the real estate would generate a documentary stamp tax of $35,000. . One of the sellers subsequently transfers her LLC interests to a corporation that she owns. The opinions expressed in this are the opinions of the author, and cannot be attributed to the law firm of Johnson, Pope, Bokor, Ruppel & Burns, LLP and its attorneys. 10 The Florida Legislature’s response is discussed later in this article. Notes and other written obligations to pay money 4. The American Influence on International Commercial Arbitration: Doctrinal Developments and Discovery Methods. the transfer was $30,000. Documents subject to the tax include: 1. Instead, contact this office by phone or in writing. The fed- eral government imposed a documentary stamp tax on transfers of real property deeds until the tax was re- pealed in 1967. (The Miami-Dade County rate is $.60 on all documents plus $.45 surtax on documents transferring anything other than a single-family residence). In the state of Florida, when property is transferred, documentary stamp tax is assessed on any outstanding mortgage debt at a rate of 70 cents per every 100 dollars. Fla. St. § 201.02 provides:This provision essentially piggybacks on the Internal Revenue Code grantor trust rules by treating transfers to grantor trusts as nontaxable events. 1. The 2007 Notice of Change of Control Legislation In 2007, the Florida Legislature enacted §193.1556, which requires any person or entity that owns nonhomestead real property to promptly notify the property appraiser of any change of ownership or control. Both parties moved for summary judgment in the circuit court, and final summary judgment was entered in favor of the DOR. According to the court, there was no consideration or purchaser with respect to the transfer of the property to CMC, since “nothing was exchanged by CMC for the grant of property from [the transferor]; [and] thus, there was no consideration or purchaser in the transaction, just a ‘mere change in form of the stockholder’s equity in the corporation.’”5 Furthermore, the court stated “[t]he argument that the increase in the value of [the transferor’s] interest in CMC constituted consideration is not persuasive, as this increased interest resulted from the transfer and was not the consideration for making the transfer.”6 The Florida Supreme Court quashed the Third District Court of Appeal’s decision and remanded the case to the district court for further consideration consistent with the Florida Supreme Court’s opinion.7. Does the Florida documentary stamp tax on deeds (the deed tax) apply to the conveyance of unencumbered Florida real property from a grantor to a wholly owned entity? An interesting consequence of the Crescent decision is its impact on ad valorem taxes and the ability of property appraisers to determine the value of Florida real estate. (Note: the doc stamp rate is $.70 per $100 for all Florida counties except Miami-Dade where the rate is $.60 per $100. The stated purpose of the transfer was to segregate the property in order to … An exception is Miami-Dade County, where the rate is $.60 per $100 (or portion thereof) when the property is a single-family residence. If the consideration paid or given in exchange for real property or any interest therein includes property other than money, it is presumed that the consideration is equal to the fair market value of the real property or interest therein.4. The Florida documentary … The amendment to the statute accomplishes this result by creating the concept of a “conduit entity,” which is defined as a legal entity to which real property is conveyed without full consideration by a grantor who owns a direct or indirect interest in the entity, or a successor entity.13 The term “full consideration” means the consideration that would be paid in an arm’s length transaction between unrelated parties.14, The amended statute provides that when real property is conveyed to a conduit entity and all or a portion of the grantor’s direct or indirect ownership interest in the conduit entity is subsequently transferred for consideration within three years of such conveyance, then tax is imposed on each such transfer of a conduit entity interest for consideration at the rate of $.70 for each $100 or fraction thereof of the consideration paid or given in exchange for the ownership interest in the conduit entity.15, When an ownership interest is transferred in a conduit entity that owns assets other than the real property conveyed to the conduit entity, the tax is prorated on the percentage the value of such real property represents of the total value of all assets owned by the conduit entity.16. If you do not want your E-mail address released in response to a public records request, do not send electronic mail to this entity. The Documentary Stamp Tax also applies to documents executed or delivered in the state of Florida. Finally, the amendment to §201.02 provides that a transfer for purposes of estate planning by a natural person of an interest in a conduit entity to an irrevocable grantor trust as described in subpart E of part I of subchapter J of chapter 1 of subtitle A of the United States Internal Revenue Code is not subject to documentary stamp tax.20 There is no requirement that the transfer to such irrevocable grantor trusts be without consideration. (Example: $50,051 rounds to $50,100 multiplied by 0.007 equals $350.70) Documentary Stamp Tax & Intangible tax for Mortgages Documentary Stamp Tax at $.35 per … The potential liabilities associated with real property can be significant, including environmental exposure and premises liability. 8 Jeff Ostrowski, Critics Push to Plug Hole in Tax Loophole, Palm Beach Post, August 12, 2007. The first lesson to be drawn is that the DOR purports to reach the use of tiered structures to make indirect transfers of conduit entities. This column is submitted on behalf of the Tax Section, Guy E. Whitesman, chair, and Michael D. Miller and Benjamin Jablow, editors. Following up on the previous example, in certain instances, there would be no need for P to dissolve S LLC, where the real estate is a commercial property. The deed was recorded, and CMC paid $1,212,750 in documentary stamp tax, which was comprised of the state documentary stamp tax and a Dade County documentary surtax. Regardless of where the deed or other document is signed and delivered, documentary stamp tax is due. In addition, the statute borrows the federal income tax concept of “grantor trusts” to define a nontaxable transfer. Code R. 12B-4.014(2)(a) (2009). 3 2009 Fla. Laws Ch. Florida imposes a documentary stamp tax of 70 cents ($1.00 in Miami-Dade) per $100 of the purchase consideration for the sale of real estate located in Florida. The DOR concludes that the transfer of stock in the corporation which holds the LLC interests is subject to documentary stamps. Rappoport & Glassman, Documentary Stamp Tax: The Legislature Strikes Back, 48 Fla. Bar. Florida imposes a documentary stamp tax on transfers of real estate by deed at a rate of $0.70 per $100 or part thereof of consideration. For purposes of this section, consideration includes, but is not limited to, the money paid or agreed to be paid; the discharge of an obligation; and the amount of any mortgage, purchase money mortgage lien, or other encumbrance, whether or not the underlying indebtedness is assumed. Outside of Miami-Dade County, the transfer tax rate is 70 cents per $100 of the deed's consideration. In other words, you can calculate the transfer tax in the following way: (Total Price/$100) x.70 = Doc Stamps Cost So, let's say you live in Key West. Although this has been included to facilitate “estate planning,” it is not entirely clear what this provision accomplishes. The State of Florida has preserved a unique, arguably antiquated stream of revenue since 1931. Calculations. Under the example, two sellers transfer the real estate into an LLC. The Florida Supreme Court held that the documentary stamp tax did not apply to the conveyance to CMC because the transaction lacked “consideration” and a “purchaser” as required by the statute. The failure to provide the required disclosure results in the ability of the property appraiser to determine for a period of 10 years that the assessed value of the property should have been higher as a result of the change in control transaction. First, a gift of an ownership interest in a conduit entity is not subject to tax to the extent that there is no consideration.17 This exception is consistent with the general rule that the documentary stamp tax does not apply to gifts of unencumbered realty.18. No. Documentary Stamp Tax at $.70 per $100, rounded up, based on the total purchase price. Additionally, there would be no public record of the consideration for the transfer of the membership interest for the property appraiser to consider in assessing the value of the property.10, The 2009 Documentary Stamp Tax Legislation In its 2009 amendment to §201.02, the Florida Legislature clearly articulated its disdain for the use of the Crescent decision as a deed tax avoidance device, stating: “The Legislature finds that the Florida Supreme Court opinion in Crescent Miami Center, LLC v. Florida Department of Revenue, 903 So. The Florida Department of Revenue (DOR) denied the application, and the transferee filed suit in Miami-Dade Circuit Court challenging the DOR’s refund denial. Since documentary stamp tax must be of concern in every conveyance of Florida real property, let's take a closer look at what it is and how it is assessed. J. A change of ownership or control generally means any sale, foreclosure, transfer of legal title or beneficial title in equity to any person, or the cumulative transfer of control or of more than 50 percent of the ownership of the legal entity that owned the property when it was most recently assessed at just value.21 The change of ownership is reported on Form DR-430, Notice of Change of Ownership or Control Non-Homestead Property, by the owner to the property appraiser in the county where the property is located. 201.02. She later sells the interests in the corporation which holds her interests in the underlying LLC. — The 10-cent tax increase in the documentary stamp tax levied by s. 2, chapter 92-317, does not apply to deeds and other taxable instruments relating to real property located in any county that has implemented the provisions of chapter 83-220, Laws of Florida, as amended by chapters 84-270, 86-152, and 89-252, Laws of Florida. S and P end up in the same exact place, except that the documentary stamp tax has been avoided. 2d 913 (Fla. 2005), that such conveyances are not subject to documentary stamp tax. Otherwise, property must be inspected every five years.9 If a membership interest in a limited liability company is sold instead of the underlying real estate, the property could conceivably escape reassessment for a number of years following the transfer of the membership interest, because a new deed would not be recorded upon such transfer. This example illustrates how the application of Crescent effectively repealed the documentary stamp tax for a significant number of real estate transactions. The tax is imposed on a tax base equal to the consideration given for the transfer, rounded up to the nearest $100. Generally, a transfer tax is imposed on documents that convey an interest in real property from one person or legal entity to another person or legal entity. He received his J.D., summa cum laude, in 2006 and his LL.M. Documentary stamp taxes did not apply to the transfer of the LLC interests. The treatment of a merger or conversion as a conveyance potentially accomplishes two goals. Florida imposes a documentary stamp tax of 70 cents ($1.00 in Miami-Dade) per $100 of the purchase consideration for the sale of real estate located in Florida. Hank transfers a Florida beach house valued at $1 million with a $750,000 mortgage balance to a LLC that is 100% owned by him. Over the years the answer to this question has shifted from “no” to “yes” and back to “no” as Florida courts and the Florida Legislature interpreted and refined the concepts of “purchaser” and “consideration” for purposes of the deed tax.1 The most recent (and presumably final) answer to this question came in 2005, when the Florida Supreme Court held in Crescent Miami Center, LLC v. Florida Department of Revenue, 903 So. 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