Redacted Letter Rulings

Written by Finance's Legal Affairs Division, letter rulings are written statements that set forth the applicability of the statutes and rules to a specific set of facts, and are provided in redacted form to protect taxpayer-specific information.

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Property Tax

Real property conveyed from a not-for-profit to a single-member limited liability company which is then leased to another not-for-profit and used for educational purposes may retain its real property tax exemption under RPTL section 420-a.  #09-4890.  6/1/2009
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Real property conveyed from a not-for-profit to a single-member limited liability company that continues to be leased to an affiliated not-for-profit and used for charitable, educational and /or mental or moral improvement purposes may retain its real property tax exemption under RPTL section 420-a.  #08-4882. 4/17/2009
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Real property owned by a not-for-profit organization in the form of a leasehold condominium where the unit owner pays all taxes attributable to its unit is eligible for a real property tax exemption under RPTL section 420-a. #08-4886. 2/13/2009
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Real property conveyed from a not-for-profit hospital to a single member limited liability company with the not-for-profit hospital as its sole member may retain its real property tax exemption under RPTL Section 420-a if the organization and conduct of the LLC and the use of the property meet qualifying criteria. #08-4874. 4/29/2008
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Real property conveyed from a not-for-profit to a single-member limited liability company in which the not-for-profit is the sole member may retain its real property tax exemption under RPTL section 420-a and will also be exempt from the RPTT. #07-4873. 11/21/2007
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A taxpayer did not qualify for LMREAP benefits as an eligible business because it was not conducting substantial business operations outside New York City for the 24 consecutive months immediately preceding the taxable year in which it would be deemed to have relocated to "eligible premises." #05-4842. 2/14/2006
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Real property conveyed from a not-for-profit organization to a single member limited liability company with the not-for-profit organization as its sole member may retain its real property tax exemption under RPTL Section 420-a if the organization and conduct of the LLC and the use of the property meet qualifying criteria. #02-4794. 6/12/2002
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