S and A Property Investment Services, LLC v. Garcia
Married owners of a non-homestead Miami rental property quitclaimed it, without consideration, to an LLC they wholly owned, and the Property Appraiser removed the 10% non-homestead assessment cap under section 193.1554(5) as a 'change of ownership.' The Third DCA affirmed summary judgment for the Property Appraiser, holding that a conveyance from individuals to their wholly owned LLC is a change of ownership and does not fall within the statutory exception for transfers 'between legal and equitable title.'
Key facts
- Married owners of a non-homestead Miami rental property quitclaimed it without consideration to an LLC they wholly owned.
- The Property Appraiser removed the 10% non-homestead assessment cap under section 193.1554(5), treating the conveyance as a 'change of ownership' and reassessing at just value.
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Why it matters
This decision closes a commonly attempted estate- and asset-protection planning maneuver: transferring rental property into a wholly owned LLC for liability insulation will reset the property tax assessment to just… — full analysis with a trial
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