1. A. A transfer of controlling interest is considered complete when the controlling interest percentage standard is met within any 12-month period, regardless of whether other transfers may be planned or have taken place outside of the 12-month period.

2. B. If a final transfer of controlling interest is accomplished through multiple steps that would be considered one transaction under the step transaction doctrine, then that one transaction, including all multiple steps that make up that one transaction, is considered effective and complete upon the earlier of the date when:

   1. (1) The last step has occurred; or
   2. (2) The interest transferred in the multiple steps meets the controlling interest percentage standard, regardless of the fact that other steps may be planned for the future.

Authority: Tax-Property Article, §§12-201, 12-103, 12-112, 12-117, and 13-202, Annotated Code of Maryland

Effective date: June 30, 2008 (35:13 Md. R. 1181)