District Of Columbia Council Bill B260396

District Of Columbia 2025-2026 Regular Session

• Introduced: 10/3/25
• Refer: 10/7/25
• Refer: 1/6/26
• Refer: 1/9/26
• Engrossed: 3/31/26
• Report Pass: 5/4/26

Caption

Transfer and Recordation Tax Appeals Amendment Act of 2025

Summary

This bill amends the District of Columbia’s transfer and recordation tax laws to create an explicit process for transferors and transferees of real property to challenge the fair market value used to calculate transfer and recordation taxes. It allows a party to first petition the Office of Tax and Revenue for administrative review of a fair market value determination, then appeal an adverse final determination to the Real Property Tax Appeals Commission, and ultimately seek review in the Superior Court of the District of Columbia if the statutory conditions are met. The measure also updates related provisions in Title 47 to align the existing appeals framework for assessed value and classification disputes with fair market value disputes arising in real property transfers. It adds deadlines, notice requirements, rehearing procedures, and payment prerequisites for appeals, and clarifies that the Commission must notify OTR of decisions involving fair market value. The bill applies to determinations under multiple transfer-tax provisions, including those tied to deed recordation and related real property transfer taxes.

Impact

The bill changes District law by expanding and clarifying administrative and judicial appeal rights for parties affected by transfer tax valuations. It amends the Real Estate Deed Recordation Tax Act and Title 47 of the D.C. Official Code to expressly authorize petitions, Commission appeals, rehearings, and Superior Court review for fair market value determinations used in calculating transfer and recordation taxes. The practical effect is to give transferors and transferees a formal avenue to contest valuation-based tax assessments and to require OTR and the Commission to process those disputes under specified timelines and procedures.

Sentiment

The bill appears to have been broadly supported and noncontroversial in the Council. It passed first reading and final reading unanimously, with 12 yeas and 0 nays on both votes. The absence of committee transcript discussion and the unanimous vote suggest general agreement that the measure is a procedural fairness and taxpayer-rights clarification rather than a contested policy change.

Contention

No major points of contention are evident in the available record. The bill’s main policy choice is to extend appeal rights to transferors and transferees over fair market value determinations, while also requiring that the tax be paid and that the party first pursue Commission review before going to Superior Court. Any potential concern would likely center on administrative burden for OTR or the Commission, or on whether the payment-before-appeal requirement could limit access to review, but no opposition is reflected in the vote history or transcripts provided.