Prang

Opinion of the Court by Evans, J.

Article XIII A of the California Constitution, added by Proposition 13, strictly limits increases in the assessed value of real property unless the property undergoes a “change in ownership.” (Cal. Const., art. XIII A, § 2, subds. (a), (b); see Citizens for Fair REU Rates v. City of Redding (2018) 6 Cal.5th 1, 10.) A change in ownership generally occurs with a transfer of real property. In a typical real estate transaction where one party transfers real property to another, there is unquestionably a change in ownership as title passes from the transferor to the transferee. Whether there has been a “change in ownership” in transactions involving a legal entity, however, is a more complex issue that can give rise to certain anomalies. If individual owners transfer real property to an entity they own, for example, it can be argued that the transfer has not caused a change in underlying “ownership,” but merely a change in the form of holding title. Likewise, when there is a significant change in the ownership of a legal entity, it can be argued that this causes a change in ownership of the entity’s real property despite no change in title. In…