This is a rule development workshop at which participation and information regarding Chapter 2009-131, L.O.F., is encouraged. This rule development workshop will assist the Department in understanding issues related to the application of the documentary stamp tax on the transfer of ownership interest in a conduit entity, as provided in Section 201.02(1)(b), F.S., as created by Chapter 2009-131, L.O.F. Persons are encouraged to participate in the rule development workshop and to submit written comments regarding the tax imposed under Chapter 2009-131, L.O.F., for the following issues: 1. Undefined Terms. The legislation uses several terms that are undefined and may require increased administration. These terms include, but are not limited to: •Legal Entity, •Arm’s length transaction, •Direct or indirect ownership, •Real property interest, and •Transfer of an interest for consideration. 2. Giving Credit for Prior Tax Paid. The legislation imposes tax on sales of ownership interests in entities after Florida real property is transferred into the entity. The statute appears to contemplate that no tax was paid when property was put into the entity. However, tax may be paid on partial consideration. The statute does not specify whether any credit should be granted for these prior taxes. 1. Mergers. The statute is silent with regard to treatment of mergers. 2. Additional Issues Related to Section 201.02(1)(b), F.S. Additional issues regarding the documentary stamp tax on the transfer of ownership interest in a conduit entity, as provided in Section 201.02(1)(b), F.S.