Court Holds State Owned LLCs Are Not "Political Subdivisions"
The California State Teachers' Retirement System ("CalSTRS"), formed two Delaware limited liability companies for the purpose of purchasing and hol...
The California State Teachers' Retirement System ("CalSTRS"), formed two Delaware limited liability companies for the purpose of purchasing and holding title to two investment properties in Alameda County, California. CalSTRS was the sole member of these LLCs and The City of Oakland and Alameda County imposed over $3.5 million in documentary transfer taxes. Both LLC agreements provided that "The purpose of the Company is to implement the essential governmental function of the Member ([CalSTRS]) by entering into that certain Contract of Sale (the ‘Purchase Agreement') between the Company and [the LLC], .