Reilly

Under Proposition 13, real property may be reassessed at its current market value when ownership of the property changes. (Pacific Southwest Realty Co. v. County of Los Angeles (1991) 1 Cal.4th 155 [ 2 Cal.Rptr.2d 536 , 820 P.2d 1046 ] (Pacific Southwest).) In this appeal, we consider whether there is a change in ownership of real property held by a testamentary trust when an income beneficiary of the trust dies and is succeeded by another income beneficiary. The City and County of San Francisco (the City) reassessed real property held by a trust after a new income beneficiary succeeded a beneficiary who died. The trustee filed suit and sought a property tax refund, arguing there was no change in ownership under Revenue and Taxation Code section 60, which generally defines what constitutes a change in ownership for purposes of reassessing property. The trial court granted summary judgment in favor of the City. We conclude there was a change in ownership under section 60 because the beneficiary’s death caused a transfer of the property’s primary economic value to the successor beneficiary, who acquired a present beneficial interest in the property. Accordingly, we affirm…