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Ruling 89-279

Controlling Interest Transfer Tax

It is represented in your letter that a trustee is the sole shareholder of a Panama corporation. The Panama corporation owns real property in Connecticut. The trustee transfers all of the shares in the Panama corporation to a Barbados corporation of which the trustee is the sole shareholder. The transfer of the shares in the Panama corporation by the trustee to the Barbados corporation is a transfer for consideration and is subject to the controlling interest transfer taxes.

If the Panama corporation is domesticated in a reorganization described in 26 U.S.C. § 368(a)(1)(F), becoming a corporation organized under the laws of the State of Delaware, the deed pursuant to the reorganization would appear not to be exempt from real estate conveyance taxes.


December 14, 1989