Title:
FACE VALUE OR PAR VALUE OF STOCKS
May 13, 1932
AGO 32-0973
DOCUMENTARY STAMP TAX - FACE VALUE OR PAR VALUE
OF STOCK DETERMINES AMOUNT
Dear Sir:
This refers to your favor of the 11th instant, in which you
make inquiry with reference to the documentary stamps required
on a situation which you state as follows:
"A holding company, whose stock is of par value of $100.00,
issues its shares of stock to acquire the shares of another
corporation, whose shares are also of par value of $100.00,
the basis of exchange, however, being two shares of the
holding company stock for one share of the corporation
stock acquired."
The second paragraph under Schedule "A", Section 1 of
Chapter 15787, Laws of Florida, Acts of 1931 (Documentary Stamp
Tax Act), among other things, has this language:
"On each original issue, whether organization or
reorganization, of certificates of stock issued in the
State of Florida, or of profits, or of interests in
property, or accumulation by any corporation, on each
$100.00 of face value or fraction thereof, 10 cents..."
It is my opinion that when the holding company issues its
stock of the par value of $100.00, that it will have to attach
to the stock books documentary stamps in the amount of 10 cents
for each $100.00 of par or face value. It seems that under the
Act it is immaterial what the consideration may be for the sale
or transfer of this stock, but that the amount of the tax is
based on the face or par value of the stock in question.
Very respectfully yours,
CARY D. LANDIS,
Attorney General.