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California Supreme Court Affirms Property Tax Reassessment After Corporate-to-Trust Transfer:

Understanding Prang v. Los Angeles County Assessment Appeals Board and Its Impact on Your Estate Plan

If you’re a California resident managing family businesses, corporate assets, or trusts, a recent California Supreme Court decision has significant implications for how you structure ownership transfers. The case of Prang v. Los Angeles County Assessment Appeals Boardclarifies when transferring property from a corporation to a revocable trust triggers property tax reassessment—potentially costing families thousands in unexpected tax increases.

## Who This Ruling Affects

This decision is particularly relevant if you:

  • Own or manage a family-owned corporation in California
  • Are planning to transfer corporate real estate to a trust
  • Have minority shareholders in your family business
  • Want to avoid unexpected property tax reassessments
  • Are creating an estate plan that includes both corporate entities and trusts
  • ## What Happened in This Case?

    Super A Foods, Inc. owned two Los Angeles supermarkets and had two classes of stock: voting and non-voting shares. In December 2014, the company transferred its properties to the Amen Family 1990 Revocable Trust.

    Here’s the critical detail that triggered reassessment:

  • The Trust owned 92.8% of Super A’s stock, including 100% of the voting stock
  • Four family members and one employee owned the remaining 7.2%
  • These minority shareholders were not beneficiaries of the Trust
  • Because the proportional ownership wasn’t identical before and after the transfer, the Los Angeles County assessor reassessed the properties for property tax purposes.

    ## The Court’s Ruling: Why Proportional Ownership Matters

    The California Supreme Court affirmed the reassessment, establishing that the transfer constituted a “change in ownership” because proportional ownership interests—measured by all stock, not just voting stock—were not identical before and after the transfer.

    This ruling means that even if a trust controls 100% of voting rights, minority shareholders create a mismatch in proportional ownership that can trigger reassessment.

    ## Key Takeaways for California Families

    1. Voting Control Alone Isn’t Enough

    California law measures ownership by total equity interest, not just voting control. Your estate planning attorney must account for all shareholders when structuring corporate-to-trust transfers.

    2. Minority Shareholders Create Tax Exposure

    If your family corporation has minority shareholders who aren’t trust beneficiaries, transferring corporate real estate to a trust may trigger significant property tax increases based on current market values.

    3. Plan Before You Transfer

    The reassessment in this case could have been avoided with proper planning. Options might include:

  • Ensuring all shareholders are trust beneficiaries in proportional amounts
  • Restructuring ownership before transferring property
  • Considering alternative transfer strategies that preserve ownership proportions
  • ## How California Probate and Trust, PC Can Help

    At California Probate and Trust, PC, we understand that California families managing business assets and trusts need comprehensive guidance that addresses both legal structure and tax implications. Our experienced estate planning attorneys help you:

  • Analyze your current ownership structure to identify potential reassessment triggers
  • Design trust-based estate plans that minimize property tax exposure
  • Coordinate corporate and trust planning to protect your family’s wealth across generations
  • Navigate complex California property tax laws that impact family businesses
  • We’ve helped thousands of California families protect their assets through transparent, personalized estate planning strategies.

    ## Take Action Now

    Don’t let an unplanned property transfer trigger unnecessary tax reassessment. Schedule a free consultation with California Probate and Trust, PC to review your family business structure and develop a tax-efficient estate plan.

    Contact us today:

  • Call (866) 674-1130
  • Visit cpt.law
  • Schedule your free estate planning consultation
  • ## Case Information

  • Case Name: Prang v. Los Angeles County Assessment Appeals Board
  • Citation: 15 Cal.5th 1152
  • Court: California Supreme Court
  • Date Filed: May 30, 2024
  • Source: California Lawyers Association
  • Full Opinion: Supreme Court Opinion PDF
  • ## Legal Disclaimer

    This article is provided for informational purposes only and does not constitute legal advice. The information contained herein is based on California law as of January 2026 and may not reflect the most current legal developments. Every estate planning situation is unique, and the applicability of the principles discussed depends on your specific circumstances. You should not act or refrain from acting based on this article without seeking professional legal counsel. Reading this article does not create an attorney-client relationship between you and California Probate and Trust, PC. For personalized legal guidance regarding your estate planning, trust administration, or property tax matters, please contact a qualified California estate planning attorney.