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California Property Tax Updates

UPDATED march 2025

California Supreme Court to Hear Olympic & Georgia Case Within the Next Couple Months

The California Supreme Court is scheduled to hear oral arguments in the Olympic & Georgia Partners LLC v. County of Los Angeles case no later than June 6, 2025.  This is the latest in a string of California appellate court cases dealing with the removal of non-taxable intangibles in the valuation and assessment of hotel and hospitality properties.  The Court of Appeal below held that the assessment on a convention hotel should have been reduced by the value of the intangible assets.  Specifically, the Court of Appeal determined that the County incorrectly assessed the hotel under the income method by including income from three non-taxable intangible assets/rights:  (1) an $80 million transient occupancy tax subsidy from the City of Los Angeles; (2) a $36 million fee discount provided by the hotel management company to the owner; and (3) $34 million in hotel enterprise assets.  Because the non-taxable intangibles directly contributed to the hotel’s success and could be quantified, the County (and the Board) erred in including the intangibles’ values in their valuation.  Olympic & Georgia Partners may be the next seminal case on California’s treatment of intangible assets in the property tax arena.  The Supreme Court’s decision will be of interest to tax attorneys in California and other states as the courts continue to wrangle with the issue of excluding non-taxable intangibles from assessment. 

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Greenberg Traurig, LLP
American Property Tax Counsel (APTC)

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