Friday, May 04, 2007

Getting Nowhere on the Real Estate Transfer Fee

The JFC tackled one of its first big budget issues yesterday with the governor's proposal to increase the real estate transfer fee from $3 per $1000 of value to $6 per $1000 of value.

The fee, which is paid by the home seller, has been at $3 per $1000 since 1984, although that doesn't seem to be a good enough reason to raise it today. As Republicans have pointed out, since the fee is rated rather than flat, it has actually increased over time as the sale price of homes has increased.

And, of course, no one wants to see the cost of selling a home increase even more. Assuming you have enough equity built up in your house, the fee may not be such a big problem. But in our increasingly mobile society and with the onset of mortgage loans that require as little as nothing down to buy, it seems likely that fewer people today have significant equity stored away when they go to sell (although my guess is that the majority still do).

But, the question becomes, if the fee isn't increased in some way, are you going to raise revenues somewhere else or cut something from the budget? (UPDATE: In the governor's budget, the state's portion of the transfer fee revenue is slated for a new county aid segregated fund.)

Republicans on the JFC not only voted against the proposed increase, they made a proposal to reduce the fee from $3 per $1000 of value to $1 per $1000 over the biennium.

This proposal, to me, was a joke. If this was a serious proposal, then it should come with an explanation of what services are going to be cut from the state budget to account for the millions it would cost over the biennium. And that's millions off the base 2005-2007 level; it would be millions more when considered in light of the proposed 2007-2009 level.

Senator Russ Decker (D-Schofield) got a lot closer to a reasonable proposal when he offered up a plan to keep the rate at $3 per $1000 of value for home sales under the state median of $200,000 and increase it to $6 per $1000 for those above that level. The exact numbers could be shifted around, but the general idea of scaling the fee makes some sense.

Unfortunately, though, Decker's idea was shot down in a party line JFC vote, which essentially ensured Doyle's proposal of $6 per $1000 of value across the board was going to stay, at least for now.

On the question of where the revenue could be made up if the rate was simply kept at $3 across the board, perhaps legislators should consider finally closing the loophole that allows some businesses to avoid paying the transfer fee at all.

It works like this: When property changes hands in the business world, it often comes along with a change in company ownership. Since this is the case, business deals are simply logged with the state as changes in who owns the company and not who owns the property.

It seems to be a distinction without a difference, but that's the way state law is currently written. Even GOP Senator Mike Ellis (R-Neenah) exclaimed back in 2003 that "it doesn't seem to be fair" that homeowners get tagged with a fee when real estate changes hands while many businesses get away without paying a thing on their property transfers.

Rep. Terese Berceau (D-Madison) sponsored a bill the past two legislative sessions that would require the transfer fee to be paid by businesses when over 50 percent of the ownership changes hands, but the proposal failed to pass the GOP-controlled legislature both times (see here and here).

Indeed, rather than double the weight placed on homeowners by increasing the rate to $6 per $1000 of value, why not just bring businesses up to snuff by making them pay the same amount that the rest of us currently do when selling real estate property?

UPDATE (5/6): Rick makes a good point about the difference between share sales and asset sales in the comments below. I'm still not sold on the argument that no property transfer is taking place when merely the ownership of a company changes, but the fact that the new ownership is assuming the old's liabilities, tax situation, etc., is an important point to keep in mind.

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30 Comments:

Blogger Dad29 said...

I agree with you that the Pubbie plan was ill-advised, at best...

They shoulda just offered one plan: take OUT the increase. Period.

On the face, Decker's alternative may have been un-Constitutional (equal proptax rule.)

And there are plenty of places to find spending which could be reduced to offset. This is NOT a major revenue item.

May 04, 2007  
Blogger Seth Zlotocha said...

If there are plenty of places to cut $142 million from the proposed budget, then Republican legislators should start pointing them out. Doing so would allow us to have a complete debate on the proposal. Currently the entirety of the increase is slated to go into the segregated fund for county aid -- is this going to be replaced with funds from somewhere else, or are we just going to cut the proposed county aid budget?

And since the real estate transfer fee isn't part of property taxes, I tend to doubt scaling it would be unconstitutional.

May 04, 2007  
Anonymous Anonymous said...

You don't need a debate on where to cut $142 million, it's never a debate when Democrats are involved, it's always "Wisconsin is in crisis", or "the sky is falling" or "the little guy is on the street" or "screw the rich, the successful or the middle class, we'll stick the bill to them". Dems DON'T debate, they lecture, yesterdays JFC hearing is prime example. They want more and more and more, and they REFUSE to cut ANYTHING, EVER!!! Want to do a budget? It's simple, you cut some from every agency, every line item, until $142 million is cut. Raising fees and taxes is not the answer, both sides of JFC should have enough political savvy to know that if it passes the Senate, it DIES in the Assembly, goes to conference committee, and won't have a chance in the world of being $3 per thousand in the end. The slobbering by some of the Milwaukee representatives and Senator Jauch, who has really never, ever had a clue what's going on around him anyway, proves that the Dems have their marching orders, will not yield, and will target the middle class until they are taxed and fee'd to death, become the poor that the Dems like to champion, and get fed up and move out of what the Dems are well on their way to achieving, making Wisconsin the highest taxed state in the nation.

May 04, 2007  
Anonymous m.z. forrest said...

30 or 60 basis points shouldn't change the economics of any real estate transaction. Yes, that $200,000 home will have a tax of $1200 rather than $600. That really shouldn't effect anyone's equity position. Brokers charge anywhere from 450 to 750 basis points for their part of the transaction.

In regard to the business end, a lot of buyouts are purchases of assets, not equity. What happens is that the targeted business's assets are bought, and the targeted business folds. At the corporate level, there may be more equity purchases, but from a taxation standpoint, asset purchases are preferred.

In the end, it does strike me as a silly tax, worthy of being eliminated.

May 04, 2007  
Blogger Seth Zlotocha said...

Wow, Anon. Most of what you wrote is so off-the-wall, it really isn't deserving of serious comment.

But I will engage you on the one point that was actually on topic. The idea that a little could be cut from every area of the budget until the $142 million is met isn't just simple, it's simplistic. Just because you spread the $142 million out doesn't mean it won't be noticed. As hard as this may be for you to believe, most of the budget areas aren't flush with cash, and even skimming a portion off the top is going to have an effect on services. And I'm not saying the sky will fall, I'm just saying it will impact services.

Which brings me back to my initial point. If Republican legislators want to get specific about what services they're willing to cut -- and that goes for all of the revenue increases they oppose, not just the transfer fee -- we'll be getting a lot closer to an honest debate on the budget. Until then, simply arguing that revenue should be cut without considering the impact on services is just as simplistic and unhelpful as arguing that services should be added without considering the cost.

M.Z.,

So the transfer fee isn't that big of a deal for families, but it should be eliminated, anyway?

$600 can be a lot of money for a middle class family, especially if it had most or all of its equity wiped out through realtor fees and a tightening housing market. It's probably not going to stop most people from selling, but that doesn't mean it's not important.

At the other end, all of the revenue from the transfer fee goes to counties, either directly or through state aid. The counties provide services that people use (parks, courts, etc.). If you simply eliminate this "silly tax," you're going to impact those services unless you shift revenue from somewhere else.

And I'm just lost on the point you're trying to make about business assets vs. equity. When a business changes ownership, the property owned by the business does, too. When homeowner property changes hands, this transfer fee is paid. When business property changes hands, the fee is not paid. Many people would consider that unfair, myself included. But to just recommend getting rid of the fee for everyone -- homeowners and businesses -- gets us right back into the services issue discussed above.

May 04, 2007  
Anonymous Anonymous said...

With some of the highest property taxes in the country, why aren't those proposing to double a fee paid only property owners being asked to justify that? Owning property does not make one cash-rich or able to give up hundreds or thousands more in equity on a property they sell. A 100% increase of a fee that produces receipts which have increased about 10% a year should be explained, not a desire to defeat such an outrageous proposal. Adding new programs, creating new funds and expanding existing programs is irresponsible in a state that has one of the highest overall tax burdens in the country as well as a structural deficit. While Governor Doyle has signed some good bills into law, his current budget proposal breaks the age-old addage that when in a hole, one should stop digging. Instead, Governor Doyle has ordered more shovels and started digging faster.

May 04, 2007  
Blogger Seth Zlotocha said...

You raise a good point, Anon, about why the burden of this fee increase is being placed on homeowners. To me, it's irresponsible to increase this fee without pulling businesses into the mix in some way. There's no good reason that real estate property transactions should come with a charge for homeowners and not businesses.

But your argument starts to veer when you try to make the tired old tax burden argument. For starters, the transfer fee isn't a tax and therefore it isn't a part of the calculation that right-wing outfits like the Tax Foundation use when figuring the so-called tax burden. Rather, the transfer fee is part of fees and assessments, or what the LFB calls "charges." And, according to the LFB, Wisconsin ranks 28th in the nation in total charges relative to personal income. And that's the dirty little secret of the fiscal conservatives in the state -- when considering all forms of revenue that comes from taxpayers, Wisconsin actually doesn't rank all that high relative to personal income. In fact, the LFB ranks Wisconsin 26th in the nation on state and local general revenue relative to personal income (17th on revenue from our own sources, and 34th on revenue from the federal government).

That LFB data can be found on page 4 of this document.

That's not to say this should be a license to raise revenues unnecessarily. But the issue really comes down to funding for services. This transfer fee increase would be specifically used, according to Doyle's budget proposal, to help counties pay for the circuit courts as well as programming for at-risk youth through the Community Youth and Family Aids Program. If Republican legislators don't think this is a wise use of public revenue, then they shouldn't be afraid object to it in those terms rather than simply hiding behind conveniently-concocted and ambiguous tax burden arguments.

May 04, 2007  
Anonymous M.Z. Forrest said...

Seth,

I'm more a fan of single source taxation. Have the counties support themselves on prop taxes. Give the State the sales tax or income tax - I would be open to going to a pure VAT for the State. Give the feds the income tax. I wouldn't be bothered if prop taxes went up because this fee is eliminated, but I do understand that there is not a whole lot of political support for my position.

My point concerning asset versus equity purchase was that I don't think this has the impact you believe, because most businesses aren't actually purchased, their assets are, so the fee would be paid. If you want to include the fee for retitling under a new entity, I don't object on principle. I just don't think there is all this lost revenue, because most businesses aren't actually purchased. It is trivial though, and I'm not sure I can explain it better than I have.

May 04, 2007  
Anonymous Anonymous said...

If this is truly an assessment and not a tax, then shouldnt the assessment just cover the cost of the services provided and not go into another fund?

May 05, 2007  
Blogger Dad29 said...

Yah..

Seth, you (and the last Anony) ID'd the problem.

Since it's a FEE, it should reflect the County's cost of updating/changing its records. If the State also maintains records, the State's COST should be reflected.

But what you have here is another in the long, long line of shell-game schemes (the worst of which is school aid) by which the State takes, then "gives" back to a third entity.

It makes the pols happy because there is no real accountability. In this little case, the Counties can pretend to be blameless (deniability is obvious,) while happily taking the money--which they have not demonstrated they NEED to offset costs.

"Federalism" accountability works at the State/County/City level, too--which is why the State and the locals have done their damndest to eliminate it.

May 05, 2007  
Blogger Rick Esenberg said...

SetH

Berceau's proposal does not "rationalize" the system or eliminate an inconsistency. It's a money grab. You can support it as that but not as anything else.

When you buy a buy a business, you can buy its assets or its shares. It is not a meaningless distinction because it effects many things, including taxes, assumption of liabilities. If you buy shares, you might avoid a transfer fee on real estate, but you'll probably wind up paying a lot more taxes in other ways - largely because of lost opportunities for depreciation.

That's why buyers almost always want to buy assets and, as m.z. points out, most deals get done that way. So the transfer fee gets paid.

If you buy shares, you are taking the corporation as an entity. You get its existing liabilities, tax situation, etc. It makes perfect sense that we would treat the assets as still held by that same entity - because they are.

So if you want to increase taxes (or charges) on business, support it. But its nothing more than that. It ignores corporate formalities and, in essence, proposes to mix apples and oranges.wshkazrd

May 06, 2007  
Blogger Seth Zlotocha said...

Rick & M.Z.,

If businesses dealings are asset purchases and therefore involve payment of the transfer fee, then there's no problem there. Those aren't the deals I was talking about.

Your explanation, Rick, of why share sales shouldn't need to pay the transfer fee makes some sense. But at least in larger sales -- such as the one described in this Wisconsin State Journal article where an Atlanta-based company avoided a $327,000 transfer fee when selling the rights to a Neenah power plant to Alliant Energy -- the moves could be construed as a financially lucrative loophole. While Alliant may have been taking over the liabilities, tax situation, etc., for the Atlanta-based company, to most observers there's still a property transfer of some sort going on there, even if the law as currently written doesn't recognize it as such. And there's also a concern that these share sales aren't reflected in property assessments since they're not officially filed as property sales, which -- at least in the short term -- can keep property taxes artifically low for the new ownership.

In the end, making all business transactions subject to the transfer fee -- or at least subject to new property assessments -- may just be a marginal reform that wouldn't take up all that much of the $142 million (although the WSJ article, which was from 2003, did note that these types of sales are an increasing trend for LLCs). But it strikes me as a conversation worth having on a larger scale alongside the discussion on increasing the transfer fee for homeowners.

Anon & Dad29,

I see your point about calling it a fee when it doesn't only pay for the services for which it was collected. I have a problem with that, too. I think M.Z. makes a good point about the logic of moving toward a single source tax, at least at the state level (local governments provide more services directly to citizens, so fees and assessments are probably more applicable there). And my point is that if every state did move to a single source tax, Wisconsin wouldn't rank nearly as high on the so-called tax burden rankings since taxes would then be a better representation of all general revenue rather than just the revenue that the states have decided to raise through taxes as opposed to charges. So while it may not make sense to use fees and assessments in some cases, such as the real estate transfer fee, the fact is Wisconsin uses them less than most states.

May 06, 2007  
Anonymous M.Z. Forrest said...

From reading the article, it seems like the law of big numbers: if the intial number is big enough, trivial dollar amounts are significnat. My favorite past of that article was speculation on the missed revenue of hundreds, maybe thousands of transactions. For simple round numbers, let's look at real-estate transactions over $1M. I did an MLS search in the GB/Manitowoc market. There are presently 5 listing exceeding $1M. The highest listing is $1.5M. At $1M, the transfer is $3K. ($10M->$30K, $100M->$300K) I'm just not seeing this windfall.

In the article, the reason for the equity purchase is stated to be not having to certify with regulators and get facilities re-licensed. This seems eminantly reasonable to me as an explanation.

May 07, 2007  
Blogger Seth Zlotocha said...

This DOR memo states that transfer fee exceptions amounted to $29 million in 2004. The total revenue collected from the fee that year was about $69 million, so the total amount exempted is fairly significant. Of course, business dealings are only a portion of that total, so that certainly reduces the amount of revenue the state could expect from applying the fee to share sales.

But a windfall of cash really isn't the point. The point is whether certain business sales should be able to avoid the fee and updating the property assessment. More specifically, should we be considering raising the fee without considering options for making all sales applicable to the fee? In short, just because it wouldn't solve the entire issue doesn't mean it's not worth considering.

That said, Rick's point about the difference between share sales and asset sales is important to keep in mind. But whether the difference is enough to negate consideration for applying the fee to share sales isn't an open and shut case. There is still a transfer of property ownership going on, and maybe it wouldn't make sense to classify it in the same way as an asset sale, but that still doesn't necessarily mean a transfer fee of some sort couldn't or shouldn't be applied. If the deal is clearly from one company to another, as opposed to between subsidiaries of the same company, then I think applying the fee makes sense.

And you're right that a share sale made sense for regulatory purposes in the case highlighted in the WSJ article; but, again, that doesn't mean applying a transfer fee to the deal is necessarily inappropriate. As the DOR memo noted: "In the last several years, avoidance of the fee appears to be increasing through the careful structuring of real estate transactions to qualify for one of the several fee exemptions." It's that "careful structuring of real estate transactions" that's particularly concerning.

May 07, 2007  
Blogger Tom said...

Thank you for raising the issue about Rep. Berceau's bill that closes this loophole in the real estate transfer fee.

I work for Rep. Berceau, so I know a little of what I speak. We have been tracking this loophole for several years now. There are a number of lawyers in Madison who make a fair income from talking their clients into moving their properties into LLCs for just this purpose.

Over $2 billion in real estate in Milwaukee has been moved into LLCs. That's over 11% of all of the real estate in Milwaukee!

Another half billion of real estate in Madison (with a billion in improvements) has been shifted into LLCs over the past few years.

All of this disappears from the assessors sight. It isn't charged real estate transfer fees when it is "sold." Neither is it re-assessed.

The cost to the state and local governments in lost revenue is enormous. Probably in the realm of tens to several hundred million dollars in lost revenue.

How is this done? Well, anyone with $150 can create an LLC on the DFI website, and transfer their property into it. The property is no longer considered "real property" but now a corporate asset. One doesn't sell their property, but a controlling share in their "pass through" entity.

It all flies below the radar. The local assessor doesn't know what the property sold for, because a real estate transfer form is not required to be filled out.

It's a mechanism to further shift the tax burden from corporate entities to single family residential owners.

May 07, 2007  
Blogger Seth Zlotocha said...

Thanks for your comment, Tom. I appreciate the info you provided; it gives some interesting detail on the DOR memo comment about "careful structuring of real estate transactions" becoming an increasingly popular trend.

May 08, 2007  
Anonymous M.Z. Forrest said...

I'm not sure to be honest with you. I hate to go anecdote here. My parents own several apartment units/buildings. About 5 years ago they reorganized them into 3 LLCs. The did not do this to avoid a 0.3% tax. They did this because it provided greater liability protection. They have since sold a few of the properties, but they didn't sell the LLCs to do it.

I don't want to run another tangent here. I will say that the State should look to eliminate LLCs because they don't serve the public interest. If folks want the liability protection, they should be forced to incorporate and have double taxation (unless they are an S-Corp, then they wouldn't face double taxation.)

The idea of tens or hundreds of millions of dollars in lost revenue is simply nonsense. $1 billion in property transfers only produces $3 million in taxes.

May 08, 2007  
Anonymous m.z. forrest said...

And that is non-recurring.

May 08, 2007  
Blogger Seth Zlotocha said...

I'm sure Tom is quite capable of defending his own statements, but I'm pretty sure his revenue figure concerned the transfer fee and lost property taxes due to the fact that property values that are a part of share sales are shielded from local assessors.

May 08, 2007  
Anonymous m.z. forrest said...

This would require believing that folks like my parents stated higher property values than their assessments when they reorganized them into LLCs. I haven't done any business reorganizations, but that seems kind of silly. Of course, my problem is that I haven't bought the causation claim, i.e. the transfer fee causes people and businesses to reorganize their property holdings into LLCs. Beside, I wouldn't anticipate the legislature making a reorganization a taxable event anyway. I'm sure llc's are sold instead of the actual property, but I do not believe that it is the preponderance of transactions your commentator alleges or that it is even common.

There is also the issue of financing arrangements that goes a little above my head. In short, I'm doubtful a bank would offer financing for structure in an LLC without something protecting their interests in case of sale. At the same time, I don't believe building owners would seek alternate financing with the resulting increased cost, just so that they could avoid a one-time fee.

May 08, 2007  
Blogger Seth Zlotocha said...

No one would claim a property value above their assessment. The issue is that the sale price of property -- as it's valued as part of a share sale -- can be significantly higher than the assessed value of the property as far as the municipality is concerned. When you buy a home, this sale price is reflected in your assessment and, subsequently, your property taxes. If you can avoid this in some business dealings, it's a potentially significant advantage to the buyer (and disadvantage to other property owners in the municipality).

May 08, 2007  
Anonymous Anonymous said...

Listen folks,
To claim that a fee is not a tax is simply ludicrous. It about the same as saying "Let's increase taxes on businesses to help the little guy"

In the first case the government reaches in to someone's pocket to fund what the pols desire.

In the second the pols delude themselves into thinking that those increased business taxes are paid by someone else besides the "little guy"

If politicians where honest they would advocate a flat tax or a straight sales tax on individuals to fund the purposes of government/ Instead they play a shell game and attempt to deceive the populous. Apparently it keeps working!

May 16, 2007  
Blogger Seth Zlotocha said...

I agree, Anon, that many fees can be dishonest, but that's not always the case. Many local units provide services -- like a special garbage pick-up or access to a public golf course, for instance -- that are assessed a fee based upon use, and that system makes sense.

But I think it would be more honest if state government limited fees to only cover the cost of the services that are provided for that fee -- such as vehicle registration -- and leave the rest to be funded through a single (or maybe dual) tax source. Making that tax source flat, however, would result in inequity, not honesty.

May 16, 2007  
Blogger Michael said...

Seth,
I agree that fees should in general be based on the services rendered.

The flat tax, though not perfect, would have nearly everyone that enjoys the benefits of our society paying toward supporting it. There would have to be some exceptions but one of the current problems is there not enough people paying taxes. Since they have dog in the fight they seldom oppose increased government spending as the taxes raised to fund it do not affect them. A national sales tax may also be effective depending on how it is structured. To get back on topic, Increased transfer fee = tax increase plain and simple. -------------------------------------------

May 18, 2007  
Blogger Seth Zlotocha said...

A flat tax is essentially a regressive tax -- it's necessarily going to hit lower income people a heck of a lot harder than the upper income people. On a broad scale, it's just not a public policy I could support.

You're not going to get any argument from me on the philosophical question of whether a fee is a tax -- not because I think it is one, but rather because I really don't think it matters what people want to call it. My only point, made far earlier in the thread, is that if GOPers want to say the revenue increases in the proposed '07-'09 are tax increases, then they shouldn't be afraid to include fees and other charges in their so-called "tax burden" rankings rather than just picking and choosing when they want to define something as a tax.

May 18, 2007  
Blogger Michael said...

"A flat tax is essentially a regressive tax -- it's necessarily going to hit lower income people a heck of a lot harder than the upper income people." Seth

The flat tax hits higher incomes worse in terms of dollar amount. Those with higher incomes already pay the lions share of collected taxes without receiving any additional "benefits" in the form of government services.

And yes I agree, all fees should be counted for tax rankings.

May 19, 2007  
Blogger Seth Zlotocha said...

A flat tax would be essentially regressive in its application because the level that you'd need to put the tax rate to keep revenues at their current level would require a significant tax increase on the lower incomes, a smaller -- but still significant -- tax increase on most in the middle incomes, and a tax decrease for most in the higher incomes.

May 20, 2007  
Blogger Michael said...

"....keep revenues at their current level..."

And that's the core of the real problem. Our politicians in both parties love to spend money and this necessitates raising "revenues". Until the spending issue is addressed there will be no tax reform that makes sense.

What problems do you see with lower income people paying taxes for the legitimate government services they receive?

May 20, 2007  
Blogger Seth Zlotocha said...

What problems do you see with lower income people paying taxes for the legitimate government services they receive?

Lower income people do pay taxes. Do you mean why can't they pay for the entire cost of those services, like in a fee-for-service set-up? The simple answer to that is they can't afford the entire cost of services like K-12 schooling or an individual health care policy...and neither can many in the middle class.

And the reason many politicians keep spending is because that's what they're constituents want. Sure, some of those same constituents would like to see their taxes cut, too, but few want to see that cut impact the services they enjoy. For instance, a recent NY Times/CBS poll asked respondents whether they'd prefer to keep the Bush tax cuts or ensure universal health care, and 76 percent opted for universal health care. For the most part, people want to have their cake and eat it, too. Politicians just want to be re-elected, so they'll gladly feed people both servings (one rhetorical, the other the real thing). Tommy Thompson didn't become one of the most popular Wisconsin governors in state history by living up to the fiscal conservative promises that first got him elected in mid-1980s -- he did it by spending like crazy in the mid-1990s.

May 21, 2007  
Blogger Tom said...

M.Z. Forrest said "The idea of tens or hundreds of millions of dollars in lost revenue is simply nonsense. $1 billion in property transfers only produces $3 million in taxes."
That's correct if:
1) you consider Madison the entire state of Wisconsin
2) you are only considering the real estate transfer fee

Milwaukee and Madison account for around 4 billion of real estate in LLCs. We have no idea yet what that is state-wide.

But, the real estate transfer fee is only the poor country cousin to the other major loss of revenue.
The real loss is that properties in LLCs are invisible to assessors, particularly when they are sold. So, an assessor has no way has no means to re-assess. Moreover, properties in LLCs are frequently sold at far over previously assessed value, so the assessor is incapable of re-assessing the property at the new market value, which is frequently in Madison, double to triple the old price. Since large apartment buildings (a favorite of LLCs) are all in LLCs, the assessor further has no means to compute comparable worth, to set the assessment. As a consequence, LLCs rich in property, go for years at assessments less than 50% of their true value. Since property taxes are computed upon tax rate times assessment, the taxes for LLC owners are quite low compared to single-family residential owners.

May 21, 2007  

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