After a Florida golf club merges into an HOA, which dues, membership contributions, and capital assessments are taxable?

Plain-English summary

The detailed response in this Florida TAA concluded that, if the merged entity qualified as a homeowners' association, dues paid by every membership class were exempt up to the lowest mandatory membership level. Higher-tier members' payments above that required minimum were taxable because those amounts were elective.

The ruling also treated membership contributions paid by equity owners and capital assessments as exempt under the separate capital-contribution rules.

The PDF's opening capsule says dues up to the mandatory level "are taxable," but that sentence conflicts with the legal analysis and formal response, which repeatedly state they are not taxable. This page follows the operative detailed response and flags the internal source inconsistency rather than repeating the capsule error.

What this means for you

Golf communities considering an HOA merger

The base amount required of every owner may qualify as an ownership-based HOA assessment. Charges above that floor for expanded recreational rights remain taxable.

Association boards

Confirm that the merged entity actually qualifies as a homeowners' association and that the facilities are common areas. The Department expressly declined to decide HOA status itself.

Accountants and tax professionals

Separate mandatory dues, optional tier upgrades, equity contributions, and capital assessments. Each category rests on a different part of Rule 12A-1.005(4).

Common questions

Q: Were dues up to the mandatory membership level taxable?
A: The detailed analysis and response say no, assuming the merged entity qualified as an HOA.

Q: What about dues above the mandatory minimum?
A: They were taxable because a member could choose the lower membership level.

Q: Were equity membership contributions taxable?
A: No. The ruling applied the equitable-ownership contribution exclusion.

Q: Were capital assessments taxable?
A: No, under the capital-assessment exclusion cited in the ruling.

Q: Why does the opening answer appear to say the opposite?
A: The opening capsule contains a contradictory "taxable" sentence; the later detailed analysis and formal response consistently say mandatory-level dues are not taxable.

Citations and references

• Fla. Stat. §§ 212.02(1), 212.04(1)(a), 720.301, 720.302, and 213.22
• Fla. Admin. Code r. 12A-1.005(4), including (4)(a)1.c., (4)(a)1.d., and (4)(d)3.

Source

• Landing page: Florida Tax Law Library
• Advisement: TAA 18A-014

Original ruling text

QUESTION: THE ISSUES INVOLVE WHETHER ANY MEMBERSHIP FEES,
CONTRIBUTIONS OR CAPITAL ASSESSMENTS RELATING TO THE USE OF
RECREATIONAL FACILITIES WOULD BE TAXABLE FOR SALES AND USE TAX
AFTER A CONTEMPLATED MERGER OF A GOLF CLUB AND A HOMEOWNER’S
ASSOCIATION.
ANSWER: TOTAL OF ALL DUES UP TO THE MANDATORY LEVELS ARE TAXABLE.
THE CONTRIBUTIONS OR CAPITAL ASSESSMENTS RELATING TO THE USE OF
RECREATIONAL FACILITIES WOULD NOT BE TAXABLE FOR SALES AND USE TAX
AFTER A CONTEMPLATED MERGER
August 31, 2018
XXX
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XXX
Re: Technical Assistance Advisement
Taxability of Facilities Dues and Assessments
Sales and Use Tax - Admissions
Sections 212.04(1)(a), 212.02(1), Florida Statutes (F.S.)
Rule 12A-1.005(4)(d)3., Florida Administrative Code (F.A.C.)
XXX
XXX
XXX
Dear XXX:
This is in response to your letter dated XXX, requesting this Department's issuance of a
Technical Assistance Advisement ("TAA") pursuant to Section 213.22, F.S., and Rule Chapter
12-11, F.A.C., regarding the taxability of certain dues and assessments after a contemplated
merger of the Club and the Association. An examination of your letter has established that you
have complied with the statutory and regulatory requirements for issuance of a TAA. Therefore,
the Department is hereby granting your request for a TAA.

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August 31, 2018
Florida Department of Revenue

Page 2
ISSUE
The issue is whether any membership fees, contributions, or capital assessments relating to the
use of recreational facilities would be taxable for sales and use tax after a contemplated merger
of the Club and the Master Association.
FACTS AS PRESENTED
Your letter provides in part the following:
The Club and the Master Association are contemplating a merger of the Club into the Master
Association ("Merger"). The proposed Merger will require approval by the members of the Club
and the Master Association. In order to accurately describe in the "member voting materials" the
potential sales tax savings associated with the Merger, we want to confirm that sales tax will not
be required to be collected on all or a portion of the membership dues formerly paid to the Club
for use of the Recreational Facilities (as hereinafter defined) after the Club is merged into the
Master Association.
The Master Association is organized as a homeowners' association in accordance with Chapters
617 and 720, F.S., for the purpose of owning and maintaining certain Common Areas and
enforcing certain restrictions beneficial to owners ("Owners") of residences (the "Lots") located
in the residential community known as XXX (the "Community"). Currently, these functions are
performed in accordance with the Master Declaration of Covenants, Conditions, Restrictions and
Easements XXXXXXXXXXXXXXXX XXXXXXXXXXX XXXXXXXXXXXXXX XXXXXXXXX
XXXXXXXX XXXXXXXXXXXX XXXXXXXXXXXXX XXXXXXXXX XXXXXXXXX (the "Existing
Declaration").
The Club is a member-owned not-for-profit Florida corporation that is owned by the equity
members ("Equity Members") of the Club. Since inception, the Club's Membership Plan and
related documents (the "Existing Club Documents") and the Existing Declaration have required
that all Owners acquire an Equity Membership in the Club. In addition, all of the Equity Members
of the Club are Owners and no person that is not an Owner may acquire an Equity Membership
in the Club.
The Club currently owns, operates and maintains certain XXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXX facilities (the "Recreational Facilities"). Pursuant to the Existing Club
Documents, the Club currently has three (3) categories of Equity Members: XXXX Members,
who are granted access to all of the Recreational Facilities; (ii) XXXX Members, who are granted
limited access XXXXXXXXX facilities and unlimited access to the balance of the Recreational
Facilities; and (iii) a XXX Member, who is granted access to the clubhouse and the swim
facilities but are not currently granted access to the XXXXXXXXXXX facilities. Currently, there
are XXXXXXX Members, XXXXXX Members and XXXXX Member.

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It is important to note that, although the Club has one XXXXXX Member, the developer of the
Community and the Club stopped offering such memberships several years ago. Significantly,
upon the sale of the Lot owned by the XXXXX Member, the XXXXX Membership will be "retired "
and no longer [be] available for issuance. The purchaser of the XXXXX Member's Lot will be
required to obtain either a XXXXX Membership or a XXX Membership.
The Club and the Master Association desire to merge in a transaction whereby the Master
Association will be the surviving corporation. Pursuant to the Plan of Merger (as hereinafter
defined), it is contemplated that, as part of the Merger and as a condition of the Merger, a
positive vote by the requisite number of Master Association and Club members will be required,
in addition to the requisite approval of their respective Boards of Directors.
Although the Club and the Master Association are still in the process of finalizing the
documentation related to the Merger, it is contemplated that the Merger will be consummated
substantially in accordance with the draft Plan of Merger attached hereto XXXXXXX (the "Plan
of Merger"). Pursuant to the Plan of Merger: (i) the Club will be merged with and into the Master
Association as authorized by § 617.0302(16), F.S.; (ii) the Master Association, as the surviving
corporation, will continue to be a Florida not-for-profit corporation and a homeowner's association
pursuant to Section 720.301(9), F.S.; and (iii) all Equity Members of the Club will remain as
members of the Master Association ("Members"), with rights, privileges and responsibilities
consistent with their categories of membership in the Master Association, as further described in
the amended and restated Declaration (the "Amended and Restated Declaration") and the
amended and restated By-Laws of the Master Association (the "Amended and Restated ByLaws"). Proposed drafts of the Amended and Restated Declaration and the Amended and
Restated By-Laws (all of such documents and the Plan of Merger are sometimes singularly and
collectively referred to as the "Merger Documents") are attached as Exhibits to the Plan of
Merger.
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX, the Master Association, as the surviving
corporation, will own and control all property previously owned by the Club.
XXXXXXXXXXXXXXXXXXXXXXXXXXXX Equity Members will exchange their Equity
Membership certificates for Recreational Facilities Certificates to be issued by the Master
Association. XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX, the holders of the Recreational
Certificates will have a preference upon liquidation of the Master Association.
Once the Merger takes place, the Master Association will own the Recreational Facilities by
operation of law. Nevertheless, the Club will also execute a deed conveying the real property
component of the Recreational Facilities to the Master Association and such facilities will
become part of the Common Areas of the Master Association. XXXXXXXXXXXXXXXXXXXXXX
once the Recreational Facilities become part of the Common Areas, each Owner will have a right
and easement of enjoyment in and to the Common Areas for their intended purposes, subject to

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the Merger Documents and the payment of Assessments and other fees or charges reasonably
imposed by the Master Association. Such easement will be perpetual and non-exclusive and will
be appurtenant to title to each Lot.
Following the Merger, XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX the Amended
and Restated By-Laws there will be three (3) categories of memberships outstanding in the
Master Association: (i) XXXX Memberships; (ii) XXXXX Memberships; and (iii) one Social
Membership. Only XXXX Memberships and XXXXX Memberships are available to purchasers of
Lots. XXXXXXXXXXXXXXXXXXXXXXXXXXXX it is contemplated that the same access rights to
the Recreational Facilities will be granted to the various categories of membership after the
Merger except that the XXXXXXXXX Member will, for the first time, also be granted limited
access to the XXXXXXXXXXXX facilities during the off season, subject to the payment of fees
and charges.
Following the Merger, XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
all Owners will have equal voting rights for "general Master Association matters", including voting
on the election of the Master Association's Board of Directors; provided that Members will
continue to be granted "weighted voting" on certain "XXXXX Matters" (i.e., certain matters
regarding rights, privileges and obligations related to XXXX Membership privileges and
obligations, XXXXXXXXXXXXXXXXXXXXXXXX) based on the same methodology as Equity
Memberships are currently weighted under the Existing Club Documents.
After the Merger, XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX it is contemplated that the
cost of owning and operating the Common Areas other than the Recreational Facilities will be
determined based on the Common Area Budget and will be shared equally by all Members as
"Common Assessments". XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX the
Common Assessments will include an allocation of such assessments for a reserve for Common
Areas, exclusive of the Recreational Facilities.
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX Members will be
assessed for the costs of owning and operating the Recreational Facilities (the "Recreational
Facilities Assessments"), which will be determined based on the Recreational Facilities Budget
and will be shared among the various categories of Members substantially similar to the manner
in which such expenses are shared by the Equity Members under the Existing Club Documents.
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX the Recreational
Facilities Assessments include the following assessments related to the Recreational Facilities
and described below: (i) the Recreational Facilities Dues Assessments, (ii) the Recreational
Facilities Membership Contributions, (iii) the Recreational Facilities Minimum Capital Reserve
Assessments, and (iv) the Recreational Facilities Member Capital Assessments.

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XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX payments required to be
paid to the Master Association for the costs of owning and operating the Recreational Facilities
(sometimes referred to as "Recreational Facilities Dues Assessments") will be shared in the
same manner as dues are shared under the Existing Club Documents such that XXXXXX
Members and XXXXXX Members will be charged XXXXXXXXXXXXXXXXXXXXXX of the
Recreational Facilities Dues Assessments charged to XXXX Members.
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX persons purchasing a
Lot will be required to make a recreational facilities membership contribution (the "Recreational
Facilities Membership Contribution") to the Master Association, the amount of which will vary
depending on the category of membership acquired. The portion of the Recreational Facilities
Membership Contribution that is retained by the Master Association on the reissuance
XXXXXXXXXXXXXX Memberships to new Members ("Resale Income") will be placed into the
Recreational Facilities Special Reserve Fund described below.
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX for each fiscal year, the
Master Association is authorized to collect the following capital assessments related to the
Recreational Facilities (the "Recreational Facilities Capital Assessments"): (i) the
Recreational Facilities Minimum Capital Reserve Assessments, which will be placed in the
Recreational Facilities Minimum Capital Reserve Fund; and (ii) the Recreational Facilities
Member Capital Assessments which will be placed in the Recreational Facilities Member Capital
Reserve Fund. The Recreational Facilities Capital Assessments will be separately stated on the
invoices for Assessments, shall each be funded as provided below and shall: (i) be placed in a
segregated account; (ii) be used solely for capital repairs, maintenance, replacements ,
improvements, expansions and additions to the Recreational Facilities (or debt service or like
items related to the financing of such items); and (iii) not be included in operating revenue or be
used to pay for operating expenses of the Master Association. Collectively, the Recreational
Facilities Minimum Capital Reserve Fund and Recreational Facilities Member Capital Reserve
Fund may be referred to as the "Recreational Facilities Capital Reserve Fund".
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX Members will be
assessed an amount XXXXXXXXXXXXXXXXXXXXX of the budgeted gross operating revenues
related to the Recreational Facilities for each Fiscal year (the "Recreational Facilities Minimum
Capital Reserve Assessments") to be placed into the Recreational Facilities Minimum Capital
Reserve Fund. The Recreational Facilities Minimum Capital Reserve Assessments shall be
allocated at the same time and in the same proportion as the Recreational Facilities Dues
Assessments.
In addition, XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX the Master
Association may require Members to pay additional capital assessments related to the
Recreational Facilities ("Recreational Facilities Member Capital Assessments"). Recreational

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Facilities Member Capital Assessments related to emergency capital repairs, maintenance and
replacements to the Recreational Facilities not available from the applicable Recreational
Facilities Capital Reserve Fund or funded indebtedness ("Replacement Assessments") may be
imposed without a vote of the Members. Recreational Facilities Member Capital Assessments
related to capital additions, expansions or improvements to the Recreational Facilities
("Expansion Assessments") may only be imposed upon approval by a majority of the votes
entitled to be cast by XXXX Members and XXXXX Members. Specifically, any Recreational
Facilities Member Capital Assessments related to the XXXXXXXXXXX facilities will be voted
upon only by the XXXX Members and the XXXXX Members, with XXXX Members having four (4)
votes and XXXXXX Members having one (1) vote for such purpose. Consistent with the Existing
Club Documents, a XXXXX Member will pay one-half (1/2) of the amount of the capital
assessment for the XXXX facilities paid by a XXXX Member. Recreational Facilities Member
Capital Assessments relating to Recreational Facilities XXXXXXXXXXXXX shall be voted on by
XXXX Members and XXXXXX Members, with each being granted one (1) vote for such purpose
and each being required to pay the same amount of Recreational Facilities Member Capital
Assessments relating to such facilities.

Similar to the Existing Club Documents, XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXthe Master Association will also continue to maintain a "Recreational Facilities
Special Reserve Fund". The Special Reserve Fund is generally funded from (i) the portions the
Recreational Facilities Minimum Capital Reserve Fund and the Recreational Facilities Member
Capital Reserve Fund that are not expended, accrued, committed or otherwise reflected in the
Master Association's financial statements or notes thereto as capital expenditures for the fiscal
year for which they were budgeted, (ii) Resale Income, (iii) any operating surplus related to the
Recreational Facilities that the Board determines should be placed in the Recreational Facilities
Special Reserve Fund, and (iv) any excess insurance proceeds received upon damage or
destruction of the Recreational Facilities. The Recreational Facilities Special Reserve Fund may
only be used for capital repairs, maintenance, replacements, additions, expansions and/or
improvements to the Recreational Facilities.
In addition to the Recreational Facilities Assessments, Members will be required to pay
mandatory service charges ("Mandatory Service Charges") on an annual basis based upon the
Member's category of membership. Mandatory Service Charges are not dependent upon a
Member's use of the Recreational Facilities and are collected for the purpose of maintaining
adequate service levels at the Recreational Facilities. Mandatory Service Charges, along with all
charges incurred for XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXgoods and
services purchased by Members from the Master Association are defined as "Club Charges"
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

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XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX an Owner's obligation to pay all
Assessments, including the Common Assessments and the Recreational Facilities Assessments,
and Club Charges is secured by a lien on such Owner's Lot. The lien is superior to all liens
placed of record (except for certain taxes and liens or charges of a first mortgagee of record) and
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX may be enforced by the Master Association by
suit, judgment or foreclosure in accordance with applicable law.

TAXPAYER POSITION
You provide in part:
We believe that the HOA Exemption should be exempt from the sales tax as admissions
Recreational Facilities Dues Assessments and Mandatory Service Charges charged to
all categories of membership up to the level of such Recreational Facilities Dues
Assessments and Mandatory Service Charges charged to XXXXX Members
XXXXXXXXXXXXXXXXXXXXXXX. On the other hand, Recreational Facilities Dues
Assessments and Mandatory Service Charges charged to XXXX Members that are
in excess of the XXXXX Member Dues Assessments and Mandatory Service Charges
XXXXXXXXXXXXXXXXX are not exempt from the sales tax on admissions, because the
XXXXXXXXX Dues are not mandatory given that new Owners are not required to obtain
a XXXX Membership.
In addition, we believe that the Equitable Ownership Exemption should exempt from the
sales tax on admissions the Recreational Facilities Membership Contribution paid by all
categories of membership.
Finally, we believe that the Capital Contributions Exemption should exempt from the
sales tax on admissions the Recreational Facilities Minimum Capital Reserve
Assessments and the Recreational Facilities Member Capital Assessments paid by all
categories of membership.
LAW AND DISCUSSION
Section 212.04(1)(a), F.S., indicates, "… [it is] the legislative intent that every person is
exercising a taxable privilege who sells or receives anything of value by way of admissions."

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Section 212.02(1), F.S., provides in part, "The term 'admissions' means and includes the net sum
of money after deduction of any federal taxes for admitting a person or vehicle or persons to any
place of amusement, sport, or recreation ... and all dues and fees paid to private clubs and
membership clubs providing recreational or physical fitness facilities, including, but not limited
to, golf, tennis, swimming, yachting, boating, athletic, exercise, and fitness facilities, except
physical fitness facilities owned or operated by any hospital licensed under chapter 395."
(Emphasis added)
It is clear that fees paid to membership clubs providing recreational facilities are subject to
sales and use tax on admissions. Taxpayer relies on Rule 12A-1.005(4)(d)3., F.A.C., to support
the contention that the subject fees are not subject to tax. The rule provides the following as an
example of fees that "... do not entitle the payor to the use of the club's recreational or physical
fitness facilities ..." and would therefore not be subject to taxation:
Mandatory dues and fees paid to a condominium association, homeowners' association, or
cooperative association when they are required to be paid as a condition of ownership or
occupancy of real property and the club facilities are part of the common elements or
common areas of the real property. (Emphasis added)
Homeowners' Associations: Homeowners' Associations are governed by Chapter 720, F.S.,
which explicitly does not apply to "the commercial or industrial parcels in a community
that contains both residential parcels and parcels intended for commercial or industrial use."
Section 720.302(3)(b), F.S.
Section 720.301(9), F.S., defines a homeowners' association as:
... a Florida corporation responsible for the operation of a community or
a mobile home subdivision in which the voting membership is made up of
parcel owners or their agents, or a combination thereof, and in which
membership is a mandatory condition of parcel ownership, and which is
authorized to impose assessments that, if unpaid, may become a lien on
the parcel. The term "homeowners' association" does not include a
community development district or other similar special taxing district
created pursuant to statute. (Emphasis added)
"Community" means "the real property that is or will be subject to a declaration of covenants
which is recorded in the county where the property is located. The term `community' also
includes all real property, including undeveloped phases, that is or was the subject of a
development-of-regional-impact development order, together with any approved modification
thereto." Section 720.301(3), F.S.

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According to Section 720.301(2), F.S., governing homeowners' associations, a "common area"
includes:
... all real property within a community which is owned or leased by an
association or dedicated for use or maintenance by the association or its
members, including, regardless of whether title has been conveyed to the
association:
(a) Real property the use of which is dedicated to the association or its
members by a recorded plat; or
(b) Real property committed by a declaration of covenants to be leased or
conveyed to the association.
The fees must be paid to a homeowners' association. It is not the responsibility, nor the
intention of the Department to construe Chapter 720, F.S., or to render an opinion as to
whether the Merged Entity will qualify as a homeowners' association after the merger.
Accordingly, we will not make a determination regarding this aspect of your request.
However, should the Merged Entity qualify, payments must be: (1) mandatory; (2) required
to be paid as a condition of the ownership of real property; and, (3) the recreational
facilities must be part of the common elements or common areas of the real property.
The XXXX Members' payments are not wholly mandatory, as a member could opt for the
XXXXX Membership.
All payments made by all classes to the extent of the XXXX Member's payment fees
would be qualified for the exemption found in Rule 12A-1.005(4)(d)3., F.A.C.1 This is
because all members must have at least one membership (mandatory). The XXXX
Member's payments are exempt up to the XXXXX Member payment amount
requirements, as that is the amount that is mandatory.
The member payments must be paid as a condition of the ownership of the real property,
and recreational facilities are part of the common elements. Accordingly, all of the
requirements of Rule 12A-1.005(4)(d)3., F.A.C., are met.
Rule 12A-1.005(4)(a)1.d., F.A.C., provides an exclusion from the tax for "Capital
contributions or additional paid-in capital paid to an organization by individuals who have
an equitable ownership interest in the organization." Accordingly, the recreational Facilities

1

Provided the Merged Entity qualifies as a homeowners' association.

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Membership Contribution paid by all categories of membership would not be subject to
sale tax.
Rule 12A-1.005(4)(a)1.c., F.A.C., provides an exclusion from taxable dues and user fees
for "[c]apital assessments levied by an organization against persons who are, or seek to
become, members of the organization."
Any capital assessments would be eligible for the exemption found in the above rule.
RESPONSE
Should the Merged Entity qualify as a homeowners' association after the merger, any
fees will not be taxable to the extent of the XXXXX Member's level of payments.
Payments in excess of these mandatory fees will be subject to sales and use tax. The
recreational Facilities Membership Contribution paid by all categories of membership
would not be subject to sale tax. In addition, Capital assessments will not be taxable.
This response constitutes a Technical Assistance Advisement under Section 213.22, F.S., which
is binding on the Department only under the facts and circumstances described in the request for
this advice as specified in Section 213.22, F.S. Our response is predicated on those facts and
the specific situation summarized above. You are advised that subsequent statutory or
administrative rule changes, or judicial interpretations of the statutes or rules, upon which this
advice is based, may subject similar future transactions to a different treatment than expressed
in this response.
You are further advised that this response, your request and related backup documents are
public records under Chapter 119, F.S., and are subject to disclosure to the public under the
conditions of Section 213.22, F.S. Confidential information must be deleted before public
disclosure. In an effort to protect confidentiality, we request you provide the undersigned with an
edited copy of your request for Technical Assistance Advisement, the backup material and this
response, deleting names, addresses and any other details which might lead to identification of
the taxpayer. Your response should be received by the Department within 15 days of the date of
this letter.

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Sincerely,

R. Clay Brower
R. Clay Brower
Revenue Program Administrator
Technical Assistance and Dispute Resolution (850) 717-6306
RCB/
CtrI # 89990