Connecticut State Department of Revenue Services

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Ruling 89-16

Controlling Interest Transfer Tax

In answer to your questions:

  1. the tax is measured by the value of the interest in Connecticut real property.
  2. the transferor of a controlling interest in the entity is the person subject to the tax.
  3. a controlling interest is, in the case of a corporation, more than 50% of the total combined voting power of all classes of stock in the corporation, and, in the case of a partnership, association, trust or other entity, more than 50% of the capital, profits or beneficial interest in the entity.
  4. the tax is due on or before the last day of the month next succeeding the month in which the transfer of a controlling interest occurs.

LEGAL DIVISION

June 16, 1989