Laws, Regulations & Annotations

C

220.0000 CHANGE IN OWNERSHIP

Annotation 220.0170

220.0170 Economic Recovery Tax Act. A "safe harbor" lease/agreement under which the seller sells only the limited right to be treated as the owner of the property "solely for federal income tax purposes" and, simultaneously, the purchaser leases back only the right to be treated as the lessee of the property "solely for federal income tax purposes" is not a change in ownership under Revenue and Taxation Code section 60. The right to take tax credits and/or depreciation is not substantially equivalent to the fee interest in the property, and there has been no transfer of the beneficial use of the property. C 11/23/1981.