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:
## 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:
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:
## 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:
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:
## Case Information
## 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.