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New York state has enacted new disclosure requirements that could apply to any limited liability company (LLC) that transfers or acquires certain residential real property in New York by deed, which could have a dramatic effect on all residential condo developers. Chapter 297 of the Laws of 2019. Absent any guidance to the contrary, if an LLC is the grantor or the grantee on any NYC residential condominium (or 1- to 4-family house) deed on or after Sept. 13, 2019, the LLC may have to attach to its NYC transfer tax return a list of all of the LLC’s direct and indirect owners, going up an unlimited number of tiers until the disclosure of all indirect owners who are individuals, as well as all of the LLC’s and its owners’ managers, officers, and authorized persons, and sometimes their managers, officers, owners, and so on. N.Y.C. Admin. Code § 11-2105.h; New York City Department of Finance, Real Property Transfer Tax (RPTT).

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