Washington State

Office of the Attorney General

Attorney General

Bob Ferguson

AGO 1954 NO. 225 > Mar 19 1954

Where an original corporation is divided into two new corporations, the real estate being transferred to one of the new corporations add the personalty to the other, the original corporation retaining all of the capital stock of the two new corporations, the transfer of real property from the original corporation to one of the new corporations constitutes a transfer subject to the real estate excise tax.  The amount of tax payable is based upon the fair market value of the stock in the new corporation which is retained by the original corporation.