State rules on top of the federal ones

1031 Exchanges in California

The federal rules are identical in every state — the 45/180-day deadlines, the intermediary, the equal-or-greater tests. What changes in California is the state tax layer: high rates, mandatory withholding with an exchange exemption, and a clawback form that follows you out of state.

State tax on the gain

California taxes capital gains as ordinary income — no discounted rate — with brackets reaching 13.3% at the top. On a large gain, the state layer alone can approach half the size of the federal bill, which makes deferral proportionally more valuable in California than almost anywhere else.

Does California recognize 1031 deferral?

Yes. California generally conforms to Section 1031 for real property, so a valid federal exchange defers California tax too. The state's caveat isn't whether you can defer — it's how carefully it tracks the deferred gain afterward.

Withholding at closing

California normally requires 3⅓% of the sale price withheld at closing on investment property sales. In a 1031 exchange, you can claim an exemption from withholding on Form 593 by certifying the sale is part of an exchange — your escrow officer handles the form, but you need to flag the exchange before closing. If the exchange later fails or produces boot, withholding applies to the taxable portion.

Exchanging into another state

This is the famous one. Exchange California property into another state, and California asserts that the deferred gain remains California-source income forever. You must file Form 3840 with the state every single year you hold the replacement property — miss the filing and the Franchise Tax Board can assess the deferred tax immediately. When you eventually sell in a taxable sale, even decades later in Texas, California expects its share of the originally deferred gain.

The annual choreForm 3840 is not hard, but it is eternal — every year, even years nothing happens, until the deferred gain is recognized or eliminated (for example, by the step-up at death). Put it on the same calendar reminder as your tax return.
Run your numbers with the California rate →The calculator takes your state tax rate — see the full deferral including the state layer

State tax rules change and have exceptions this page can't cover. Confirm current rates and filing requirements with a tax professional licensed in California.

Common Questions

Does California allow 1031 exchanges?

Yes — California conforms to the federal rules for real property, and a valid exchange defers state tax alongside federal. The state adds withholding paperwork at closing and the annual Form 3840 filing if you exchange into out-of-state property.

What is California Form 3840?

An annual information return that tracks gain deferred when California property is exchanged for out-of-state property. It must be filed every year you hold the replacement property; failing to file lets the state assess the deferred tax immediately.

Can I escape California tax by exchanging into Nevada or Texas property?

No. The clawback rule sources the deferred gain to California permanently. Moving the real estate (or yourself) out of state defers but does not eliminate the California claim — though holding until death can, via the step-up in basis.