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The Borrelli Report · 1031 Exchanges

The filing thresholds are for people who work there.
You own there.

Twenty-two states require a nonresident return on any income sourced inside them. The day-based safe harbours the other states publish are written for wages — and a partnership K-1 does not care how many days you visited.

The trap

One 721 exchange. Twelve state returns.

A 721 exchange puts your property into an operating partnership and hands you units in return. The work stops. The partnership now owns buildings in a dozen states — and its K-1 allocates a slice of income to every one of them.

Each of those states with an income tax can require a nonresident return from you. Whether it actually does depends on four things the K-1 does not say: how much was allocated there, what that state’s floor is for that kind of income, whether the partnership filed a composite return on your behalf, and whether tax was withheld at the entity level.

Why the published thresholds mislead. When a state says nonresidents can skip filing under 30 days, it means thirty days working there. That protects a consultant on a project. It does nothing for someone whose income comes from a building — that income is sourced to the state every day of the year, whether or not you ever set foot in it.

A client of mine was billed a serious sum by his CPA just to work out which states applied. Not to file — to find out. This page does that part.

Build your list

Tick every state where you hold property — directly or through a partnership.

Gold tiles have no individual income tax. Everywhere else, assume a question until your CPA says otherwise.

Tap each state that applies to you
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Get the question set for your states

One email, built for the states you ticked: what each one publishes, why it probably does not protect property income, and the exact questions to put to your CPA — with the source cited for every one.

Changes which questions go in. Partnership income adds composite returns and entity-level withholding to the list.
Professionals get the same report and none of the follow-up. If it is useful, it is yours to use with clients.

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Quick answers

The questions people actually ask.

Do I have to file where I own rental property but do not live?

Almost always, if the state has an income tax. Most states require a nonresident return on any income sourced there, and the day-based safe harbours apply to wages earned working in the state, not to income from property held there. A handful of states have dollar floors that may exempt very small amounts — your CPA can confirm whether the floor reaches rental income.

Why did a 721 exchange create obligations in so many states?

You now hold units in a partnership that owns property across many states. Its K-1 allocates income to each, and each one with an income tax can require a return. Whether you must actually file depends on the allocation size, the state’s floor, whether a composite return was filed, and whether tax was withheld at the entity level.

What is a composite return?

A single return the partnership files for its nonresident partners in a state, paying the tax on their behalf. Where one is filed and you are included, you generally do not file separately there. Not every state allows it and not every partnership elects it.

Will I be taxed twice?

Usually not. Home states generally credit tax paid elsewhere on the same income. The burden is the compliance — several extra returns a year — not double tax.

Source