Ruling 89-207

Real Estate Conveyance Tax

Where a conveyance of realty is made in exchange for the conveyance of other realty, each conveyance is subject to State and municipal real estate conveyance taxes. Conn. Agencies Regs. § 12-494-2(a)(2). If Taxpayer A quit-claims his interest in 92 Farmington Avenue to Taxpayer B in exchange for Taxpayer B quit-claiming his interest in 1 Market Street to Taxpayer A, each releasor will have made a taxable conveyance. The measure of each releasor's tax liability will be the fair market value (unreduced by the amount of any encumbrances) of the interest in realty conveyed thereto.

LEGAL DIVISION

November 9, 1989