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For California sellers

California 1031 clawback & FTB Form 3840, explained

Exchanging California property into Nevada defers California tax. It doesn't end California's interest in that gain. Here's how the tracking works and how investors plan around it.

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By Ken Calder, Broker/Owner, You Decide Realty · NV Lic. B.1001776 · 30+ years in Nevada real estate · Updated September 26, 2026
How it works

What is the California 1031 clawback?

California's "clawback" rule lets California tax gain you deferred on California property, even after you exchanged into property in another state. California doesn't collect the tax at the time of the exchange. Instead it tracks the deferred gain and collects it when you eventually sell the out-of-state replacement in a taxable sale.

The tracking tool is FTB Form 3840, California Like-Kind Exchanges. It applies to exchanges of California property for property outside California that occurred in taxable years beginning on or after January 1, 2014.

SituationWhat California generally expects
Year you exchange California property for Nevada propertyFile FTB 3840 with your California return (or on its own if you have no other filing requirement)
Each year you keep holding the Nevada propertyFile FTB 3840 annually, even with no other California income
You sell the Nevada property in a taxable saleReport and pay California tax on the gain deferred from the California property
You 1031 the Nevada property into another propertyDeferral continues; keep filing FTB 3840 on the new replacement
You stop filing FTB 3840The FTB can send notices and may estimate and assess tax on the deferred gain

Form and instructions: California Franchise Tax Board forms search (search "3840").

Planning

Planning around the clawback

Only the California gain is tracked

The clawback applies to the gain that was deferred from the California property. Appreciation on the Nevada replacement after the exchange is generally treated separately. For a Nevada resident, that later appreciation isn't California-source income. Your CPA should keep a clear record of the gain at the time of the exchange.

Keeping the deferral going

Nothing forces you to cash out. Many investors exchange again and again, staying in real estate and carrying the deferred gain forward, while filing FTB 3840 each year.

What happens at death

Under current federal law, heirs generally receive a stepped-up basis in inherited property, which can eliminate the deferred federal gain. Whether and how that affects California's tracked gain is a question for your estate attorney and CPA. Don't assume either way.

Common mistakes

  • Forgetting to file FTB 3840 after moving out of California.
  • Assuming a residency change erased the California gain.
  • Losing the records that show how much gain was deferred at the time of the exchange.
  • Not claiming the Form 593 withholding exemption at the California closing.
What would you owe without a 1031?
A quick illustration of the federal and state tax a sale could trigger. Numbers stay in your browser.
Total gain
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Federal (CG + recapture)
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NIIT
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State / city
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Est. tax a 1031 could defer
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Illustration only, using top marginal rates: federal long-term capital gains on gain above depreciation, up to 25% on depreciation recapture (unrecaptured §1250 gain), optional 3.8% NIIT, and the selected state's top 2026 income-tax rate (Tax Foundation). Actual tax depends on brackets, residency, sourcing, and deductions. Not tax advice; have your CPA run your numbers.
Common questions

California 1031 Clawback FAQ

What is FTB Form 3840?▼
It's California's annual information return for like-kind exchanges where California property was exchanged for property outside California. It lets the Franchise Tax Board track deferred California gain.
How long do I have to file FTB 3840?▼
Generally for the year of the exchange and every later year you hold the out-of-state replacement property, until the deferred gain is recognized.
Does the clawback apply if I've moved to Nevada?▼
Generally yes. The deferred gain came from California property, so California keeps its claim on that gain regardless of where you live when you later sell.
Can I avoid the California clawback?▼
You can keep deferring it by continuing to exchange rather than selling in a taxable sale. Whether any strategy eliminates it depends on your facts; ask a California CPA or tax attorney.
Does the clawback apply to gain on the Nevada property itself?▼
Generally the clawback targets the gain deferred from the California property. Later appreciation on the Nevada property is treated separately. Confirm your specific allocation with your CPA.
Free consultation
Talk through your exchange with Ken

Tell us where you are in the sale. A licensed Nevada broker responds within one business day, usually the same day. We coordinate with your QI, CPA, and attorney; we don't replace them.

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