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<regulation prefix="Regulation" num=".11" citation="COMAR 18.13.02.11" title_num="18" subtitle_num="13" chapter_num="02" heading="Examples.">
  <text>A Delaware limited liability company (DE LLC) owns only Maryland real property with a value of $10,000,000. A New Jersey corporation (NJ Corp) owns all of the membership interest in DE LLC, which represents 100 percent of NJ Corp's assets. A California corporation (CA Corp) owns all of the stock of NJ Corp and all of the membership interest in a Florida limited liability company (FL LLC), which represents 100 percent of CA Corp's assets. FL LLC owns only Florida real property valued at $1,000,000. The following apply:</text>
  <paragraph num="A.">
    <text>The transfer of DE LLC's membership interest is subject to recordation and transfer taxes in Maryland under Tax-Property Article, §12-117, Annotated Code of Maryland;</text>
  </paragraph>
  <paragraph num="B.">
    <text>The transfer of the stock of NJ Corp is subject to recordation and transfer taxes in Maryland under Tax-Property Article, §12-117, Annotated Code of Maryland;</text>
  </paragraph>
  <paragraph num="C.">
    <text>The transfer of the stock of CA Corp is subject to recordation and transfer taxes in Maryland under Tax-Property Article, §12-117, Annotated Code of Maryland, because 80 percent of its assets are still Maryland real property; and</text>
  </paragraph>
  <paragraph num="D.">
    <text>In §C of this regulation, if FL LLC owns only Florida real property valued at $5,000,000, the transfer of the stock of CA Corp is not subject to recordation and transfer taxes in Maryland under Tax-Property Article, §12-117, Annotated Code of Maryland, because CA Corp would no longer be a real property entity.</text>
  </paragraph>
</regulation>