The Department will administer Tax-Property Article, §12-117, Annotated Code of Maryland, and this chapter in the broadest legal manner to impose a tax when a transaction involving a transfer of controlling interest in a real property entity is structured to avoid the payment of the taxes.

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)