MEMO: New Tax Law Section 1409 – New Requirements for TP-584 and NYC RPT Forms

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Amy Jasiewicz
Sep 26, 2019 3:22 PM
Amy Jasiewicz
On September 13, 2019, Governor Cuomo signed into law an amendment to Section 1409(a) of the NY Tax Law requiring additional information to be provided upon filing Form TP-584 when the grantor or grantee of a 1-4 family residence, is an LLC.  The new law is effective immediately and requires the identification of the names and business addresses of all members, managers and other authorized persons of the LLC.  The statute goes on to state that if a member, manager or authorized person is itself any type of business entity (not just an LLC) the names and addresses of shareholders, directors, and authorized persons need to be provided until full disclosure of ultimate ownership by natural persons is achieved.  The New York State Department of Taxation and Finance has not yet amended Form TP-584 and we are unsure to what extent the statute will require disclosure in situations where large companies, estates, trusts or the like are among the members, managers or authorized persons.  In any event, it is our understanding that county clerks will immediately being enforcing the law.

Jerry Antetomaso, Esq.
Chair
Real Property Law Section
Evans Fox LLP

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Amy Jasiewicz
New York State Bar Association
Albany NY
(518) 463-3200
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Editor’s Note:

Click through and scroll down for interim forms from A&G Title…

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