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New Law Requires Full Disclosure of LLC Members
On Friday, September 13, 2019, Governor Cuomo signed a bill that went into effect immediately, A7190/S1730 amends §1409 of the Tax Law and §11-2105 of the Administrative Code of the City of New York.
The law requires that when a grantor or grantee residential property is an LLC, all members be identified.
If a member of the LLC is another LLC or other business entity, the “members, managers or authorized persons” of said LLC or entity must be listed. This must continue until ultimate ownership by a natural person is achieved.
Link to text of A7190/S1730
There are many unanswered questions regarding the implementation of the new law; we will keep you advised as we learn the answers.
What Now?
•     The NYSLTA is drafting a letter to the Commissioner of Taxation detailing our concerns with the law, challenges of compliance and request guidance.
•   The Association has been in communication with staff at the Department of Taxation & Finance to monitor their management of this matter.
•   The Association has also reached out to the NYS Bar Association and the County Clerk’s Association to collaborate on providing consistent information to our members and to the real estate finance community.

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