Under title 11, chapter 21 of the Administrative Code of the City of New York, a REIT transfer subject to the reduced RPPT rate occurs, where, as relevant here, there is an instrument transferring real property or an economic interest therein to a newly formed REIT, the value of the ownership interests in the REIT received by the grantor as consideration for the transfer is at least 40% of the value of the equity interest in the real property or economic interest therein...
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