Closing questions

Who pays transfer tax on a sponsor sale?

Sponsor sales usually shift the state and city transfer taxes to the purchaser, and the amount is grossed up. How the offering plan controls the allocation.

Who pays transfer tax on a sponsor sale?

Quick Answer

On most sponsor sales the purchaser pays, because the offering plan shifts the New York State transfer tax and the New York City real property transfer tax to the buyer. The taxes are then grossed up, since a tax the purchaser pays for the seller is itself treated as additional consideration.

Ordinarily the grantor pays the New York State transfer tax and the New York City real property transfer tax. Sponsor sales invert that by contract. The offering plan and the sponsor’s form of contract place both taxes on the purchaser, along with the sponsor’s attorney fee in many plans, and the terms are rarely negotiable.

The gross-up follows from how consideration is measured. When a purchaser pays a tax that is legally the seller’s obligation, that payment counts as part of what the seller received, so the taxable consideration rises and the tax computed on it rises with it. The forms handle the arithmetic, but the result surprises purchasers who budgeted for the base figure.

This sits on a buyer side that already carries the mansion tax on qualifying residential purchases and, on a condominium, mortgage recording tax on a financed deal. Stacking those charges is the reason a sponsor unit that looks priced in line with resales can settle out well above one.

The fix is arithmetic done early. Ask the sponsor’s counsel for a closing cost estimate that shows every buyer-side line, then compare the all-in figure against a resale in the same building rather than comparing asking prices. That comparison, done before the contract, is the point at which the allocation still has any negotiating value.

Is the transfer tax gross-up negotiable on a sponsor sale?

Rarely on the allocation itself, because the plan sets it and the sponsor applies the same terms across the building. What is sometimes negotiable is price, a work credit, or the sponsor’s attorney fee. Treat the tax allocation as a fixed cost of that unit and negotiate the number that can actually move.

Do sponsor transfer taxes apply to condo units too?

Yes. A sponsor selling new development or unsold condominium units commonly shifts the state and city transfer taxes to the purchaser in the same way, and the same gross-up applies. On a condominium the purchaser is also facing mortgage recording tax on a financed deal, so the buyer side is heavier still.

What else should you read before closing?

In the glossary

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