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SB0704 • 2026

Maryland Estate Tax – Qualified Agricultural Property – Transfer to Limited Liability Company

Maryland Estate Tax – Qualified Agricultural Property – Transfer to Limited Liability Company

Agriculture Budget Taxes
Enacted

This bill passed the Legislature and reached final enactment based on the latest official action.

Sponsor
Senator Mautz
Last action
2026-05-12
Official status
Approved by the Governor - Chapter 551
Effective date
2026-07-01

Plain English Breakdown

The official source material does not provide details on the exemption amount for agricultural property from Maryland estate tax.

Maryland Estate Tax Changes for Agricultural Property

This law allows certain people to transfer farmland to a limited liability company without paying estate tax, as long as it stays in farming use.

What This Bill Does

  • Allows qualified recipients to transfer agricultural property to a limited liability company (LLC) without being subject to estate tax recapture if specific conditions are met.
  • Requires that the LLC's ownership must only consist of qualified recipients for the property to avoid estate tax recapture.
  • Specifies that the transferred property must be used for farming purposes for at least 10 years after the original owner’s death to avoid estate tax recapture.

Who It Names or Affects

  • People who own farmland and want to transfer it to an LLC without paying estate taxes.
  • Qualified recipients who inherit or receive agricultural property for farming purposes.
  • The Comptroller, who must create rules to follow this law.

Terms To Know

qualified recipient
An individual who agrees to use farmland for farming after the original owner's death.
limited liability company (LLC)
A type of business structure that combines elements of a corporation and a partnership, offering personal asset protection to its members.

Limits and Unknowns

  • The law only applies to agricultural property used for farming purposes.
  • It is unclear how the Comptroller will implement regulations for this new provision.
  • This act takes effect on July 1, 2026, and applies to people who die after June 30, 2026.

Amendments

These notes stay tied to the official amendment files and metadata from the legislature.

283425/1

None

Favorable with Amendments { 283425/1

Plain English: AMENDMENT TO SENATE BILL 704 (First Reading File Bill) On page 3, strike beginning with “July” in line 1 down through the second “2026” in line 2 and substitute “July 1, 2027”.

  • AMENDMENT TO SENATE BILL 704 (First Reading File Bill) On page 3, strike beginning with “July” in line 1 down through the second “2026” in line 2 and substitute “July 1, 2027”.
  • SB0704/283425/1 BY: Budget and Taxation Committee

Bill History

  1. 2026-05-12 Post Passage

    Approved by the Governor - Chapter 551

  2. 2026-04-11 House

    Favorable Report by Ways and Means

  3. 2026-04-02 House

    Third Reading Passed (134-0)

  4. 2026-03-27 House

    Favorable Adopted Second Reading Passed

  5. 2026-03-27 Senate

    Returned Passed

  6. 2026-03-25 House

    Hearing 4/02 at 1:00 p.m.

  7. 2026-03-18 Senate

    Favorable with Amendments Report by Budget and Taxation

  8. 2026-03-09 House

    Referred Ways and Means

  9. 2026-03-05 Senate

    Third Reading Passed (42-0)

  10. 2026-03-03 Senate

    Favorable with Amendments { 283425/1 Adopted

  11. 2026-03-03 Senate

    Second Reading Passed with Amendments

  12. 2026-03-02 Senate

    Favorable with Amendments { 283425/1

  13. 2026-03-02 Senate

    Motion Special Order until Later Today (Senator King) Adopted

  14. 2026-02-13 Senate

    Hearing 3/04 at 1:00 p.m.

  15. 2026-02-06 Senate

    First Reading Budget and Taxation

  16. Maryland General Assembly

    Text - First - Maryland Estate Tax – Qualified Agricultural Property – Transfer to Limited Liability Company

  17. Maryland General Assembly

    Vote - Senate - Committee - Budget and Taxation

  18. Maryland General Assembly

    Text - Third - Maryland Estate Tax – Qualified Agricultural Property – Transfer to Limited Liability Company

  19. Maryland General Assembly

    Vote - House - Committee - Ways and Means

  20. Maryland General Assembly

    Text - Chapter - Maryland Estate Tax – Qualified Agricultural Property – Transfer to Limited Liability Company

Official Summary Text

Authorizing, for purposes of determining the Maryland estate tax, a qualified recipient to transfer ownership of qualified agricultural property to a limited liability company; providing that qualified agricultural property transferred in accordance with the Act is not subject to estate tax recapture if the ownership of the company consists only of qualified recipients and the property is used for farming purposes for at least 10 years after the decedent's death; etc.

Current Bill Text

Read the full stored bill text
EXPLANATION: CAPITALS INDICATE MATTER ADDED TO EXISTING LAW.
[Brackets] indicate matter deleted from existing law.
Underlining indicates amendments to bill.
Strike out indicates matter stricken from the bill by amendment or deleted from the law by
amendment.
*sb0704*

SENATE BILL 704
Q7 6lr3152

By: Senator Mautz
Introduced and read first time: February 6, 2026
Assigned to: Budget and Taxation
Committee Report: Favorable with amendments
Senate action: Adopted
Read second time: March 3, 2026

CHAPTER ______

AN ACT concerning 1

Maryland Estate Tax – Qualified Agricultural Property – Transfer to Limited 2
Liability Company 3

FOR the purpose of authorizing, for purposes of determining the Maryland estate tax, a 4
qualified recipient to transfer qualified agricultural property to a limited liability 5
company; providing that qualified agricultural property transferred in accordance 6
with this Act is not subject to estate tax recapture under certain circumstances; and 7
generally relating to the Maryland estate tax. 8

BY repealing and reenacting, with amendments, 9
Article – Tax – General 10
Section 7–309(c) 11
Annotated Code of Maryland 12
(2022 Replacement Volume and 2025 Supplement) 13

SECTION 1. BE IT ENACTED BY THE GENERAL ASSEMBLY OF MARYLAND, 14
That the Laws of Maryland read as follows: 15

Article – Tax – General 16

7–309. 17

(c) (1) (i) In this subsection the following words have the meanings 18
indicated. 19

2 SENATE BILL 704

(ii) “Farming purposes” has the meaning stated in § 2032A(e)(5) of 1
the Internal Revenue Code. 2

(iii) “Qualified agricultural property” means real or personal 3
property that is used primarily for farming purposes. 4

(iv) “Qualified recipient” means an individual who enters into an 5
agreement to use qualified agricultural property for farming purposes after the decedent’s 6
death. 7

(2) The Maryland estate tax shall be determined by excluding from the 8
value of the gross estate up to $5,000,000 of the value of qualified a gricultural property 9
that passes from the decedent to or for the use of a qualified recipient. 10

(3) If the value of qualified agricultural property that passes from the 11
decedent to or for the use of a qualified recipient exceeds $5,000,000, the Maryland estate 12
tax imposed on the Maryland estate of the decedent may not exceed the sum of: 13

(i) 16% of the amount by which the decedent’s taxable estate, 14
excluding the value of all qualified agricultural property that passes from the decedent to 15
or for the us e of a qualified recipient, exceeds the applicable exclusion amount specified 16
under subsection (b) of this section; and 17

(ii) 5% of the amount by which the value of qualified agricultural 18
property that passes from the decedent to or for the use of a qua lified recipient exceeds 19
$5,000,000. 20

(4) (i) The Maryland estate tax shall be recaptured as provided in this 21
paragraph if, within 10 years after the decedent’s death, the qualified agricultural property 22
ceases to be used for farming purposes. 23

(ii) The amount of the estate tax imposed under this paragraph shall 24
be the additional Maryland estate tax that would have been payable at the time of the 25
decedent’s death but for the provisions under paragraphs (2) and (3) of this subsection. 26

(5) (I) A QUALIFIED RECIPIENT MAY T RANSFER LEGAL 27
OWNERSHIP OF QUALIFI ED AGRICULTURAL PROP ERTY TO A LIMITED LI ABILITY 28
COMPANY. 29

(II) A TRANSFER OF QUALIFIE D AGRICULTURAL PROPE RTY IN 30
ACCORDANCE WITH SUBP ARAGRAPH (I) OF THIS PARAGRAPH IS NOT SUBJECT TO 31
RECAPTURE UNDER PARAGRAPH (4) OF THIS SUBSECTION IF: 32

1. THE OWNERSHIP OF THE LIMITED LIABILITY 33
COMPANY CONSISTS ONLY OF QUALIFIED RECIPIENTS; AND 34

SENATE BILL 704 3

2. THE QUALIFIED AGRICU LTURAL PROPERTY IS U SED 1
FOR FARMING PURPOSES FOR AT LEAST 10 YEARS AFTER THE DECEDENT’S DEATH. 2

(6) The Comptroller shall adopt regulations to implement this subsection. 3

SECTION 2. AND BE IT FURTHER ENACTED, That this Act shall take effect July 4
1, 2026, and shall be applicable to decedents dying after June 30, 2026 July 1, 2027. 5

Approved:
________________________________________________________________________________
Governor.
________________________________________________________________________________
President of the Senate.
________________________________________________________________________________
Speaker of the House of Delegates.