Duea

—Article XIIIA of the California Constitution (article XIII A), adopted by voters in 1978 as Proposition 13, limits the ad valorem tax on real property to 1 percent of the property’s “full cash value.” (Art. XUI A, § 1, subd. (a).) The term “full cash value” means the “county assessor’s valuation of real property as shown on the 1975-76 tax bill,” or, as relevant here, “thereafter, the appraised value of real property when purchased, newly constructed, or a change in ownership has occurred after the 1975 assessment.” (Id., § 2, subd. (a), italics added.)

As also relevant here, on a change of ownership the property is reassessed at a new base year value (e.g., revalued at current fair market value) as of the date of the transfer. (Art. XIII A, § 1, subd. (a); see also Rev. & Tax. Code, 1 § 110.1, subd. (a)(2) [“For purposes of subdivision (a) of Section 2 of Article XIIIA , ‘full cash value’ of real property . . . means the fair market value as determined pursuant to Section 110 ... : ['[[] . . . [f] (2) [f]or property which . . . changes ownership after the 1975 lien date . . . .”].)

*694 The California Constitution exempts certain transfers that otherwise would be a…