The Department of Taxation and Finance has ruled that the transfer of tangible personal property to a New York limited liability company in exchange for a pro rata share of an interest in the LLC is not a retail sale subject to sales and use tax. Advisory Opinion, TSB-A-14(23)S (N.Y.S. Dep’t of Taxation & Fin., July 22, 2014). The Department applied the provision under the Tax Law that specifically excludes from sales tax the contribution of property to a partnership in exchange for a partnership interest, noting that under Tax Law § 2(6), a “partnership” includes a limited liability company.