Limited-liability companies (LLCs) that the California State Teachers’ Retirement System (CalSTRS) had created for the purpose of purchasing and holding title to two investment properties filed a petition for writ of mandate to obtain refunds of documentary-transfer taxes that they had paid to county and city, which was based on argument that they, like their sole member, CalSTRS, were “political subdivisions” of the state and therefore exempt from the taxes.
Following a bench trial, the Superior Court denied petition. LLCs appealed.
The Court of Appeal held that the LLCs were not exempt from having to pay the documentary-transfer taxes.
Limited-liability companies (LLCs) that the California State Teachers’ Retirement System (CalSTRS) had created for the purpose of purchasing and holding title to two investment properties were not exempt from having to pay documentary-transfer taxes to city and county.