Tax Deep-Dives · 721 UPREIT · Federal · State
Federal deferral under Section 1031 is straightforward. Section 721 UPREIT contributions are not. State tax is where the second layer of complexity lives: clawback statutes, multi-year filing obligations, withholding rules, and the mechanics of replacement states with no income tax. We publish detailed analysis on each dimension.
TAX · SECTION 721 · 2026
A 721 UPREIT contribution defers gain at the moment property is exchanged for operating-partnership units, but the basis carryover, distribution rules, and eventual conversion to REIT shares trigger consequences that look nothing like a 1031.
TAX · CALIFORNIA · 2026
California's Franchise Tax Board can follow a 1031 investor across state lines for years after the exchange closes. Understanding Form 593, the clawback statute, and Mello-Roos obligations is required reading before any California sale.
TAX · MULTI-STATE · 2026
Four major 1031 destination states impose no personal income tax on capital gains from real estate sales. The mechanics differ by state, and out-of-state buyers face distinct considerations in each market.