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October 30, 2007

Det. No. 06-0289, 26 WTD 244 (2007) - Two partnerships comprised of several business entities planned to contribute their assets and liabilities, including ownership of two apartment buildings located in Washington, to another partnership (OP) in return for partnership interests in the other partnership.  The two partnerships and their partners requested a ruling from the Taxpayer Information & Education (TI&E) section of the Department of Revenue that their transaction would be exempt from real estate excise tax (REET).  We agree with the partnerships that the transaction is exempt from REET and we reverse the TI&E letter ruling, which concluded that the proposed transaction was not tax exempt.

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