Black Stone Minerals Acquisition Tax Strategy

Black Stone / Kimbell / Brigham Royalty Sale: Defer the Tax

The mineral rights consolidation cycle continues. Black Stone Minerals (NYSE: BSM), Kimbell Royalty Partners (NYSE: KRP), Brigham Minerals (NYSE: MNRL), Sitio Royalties (NYSE: STR), Viper Energy Partners (NASDAQ: VNOM), PHX Minerals, and private mineral aggregators pay strong multiples for producing acreage in the Permian, Eagle Ford, Bakken, Haynesville, and Marcellus.

A $3M royalty interest sale with $50K basis (inherited or low purchase) = $2.95M gain. Lump-sum tax = $1.1M+ in year one for CA / NY residents.

The math: $3M mineral / royalty sale, low basis

StateLump-sum tax10-yr §453Delta
California~$1.13M (38%)~$0.72M (24%)$407K
New York~$1.04M~$0.65M$390K
Oklahoma~$0.85M~$0.55M$300K
Texas / Wyoming / SD / Florida~$0.71M~$0.43M$280K
North Dakota~$0.78M~$0.50M$280K

Black Stone / Kimbell / Brigham deal mechanics

  1. NMA (Net Mineral Acres) valuation. Priced per NMA, based on cash flow + remaining reserves.
  2. Producing vs non-producing acreage. Different valuations.
  3. Royalty interest vs working interest. Royalty = capital gain on sale. Working interest = mixed character.
  4. Percentage depletion (15%) deduction stream ends at sale.
  5. Inherited basis (step-up at death) may reduce the gain meaningfully.
  6. Closing typically takes 60-90 days. §453 paperwork fits easily.
Before you read further

What is the tax bill on your sale going to be?

Send me the sale price and rough basis. Within one business day I'll email you the actual number and the Seller's Guide to §453. If it doesn't fit your deal, I'll tell you that plainly.

Hans Goldstein, EA
Admitted to practice before the IRS

No retainer · no obligation. Hans Goldstein, a licensed insurance agent (CA Insurance License #4273294), will contact you and may discuss insurance products, including annuities.

When this fits

  • $1M+ royalty interest sale (carrier minimums)
  • Royalty (not working) interest
  • Producing acreage with cash flow record
  • Major aggregator buyer (all have done §453)

How I work

Hans Goldstein, EA, IRC §453 specialist. Admitted to practice before the IRS. Placements with highly rated life insurers (A or better by A.M. Best or equivalent) in all 50 states. Free fit-check.

Hans Goldstein

Find out what your sale is really going to cost you in tax, and what you can do about it

No retainer. On a funded structure, the insurer pays a one-time commission of about 4% of the amount structured to the brokerage firm that places it (Hans’s share is about 2.4%; no trail). It is built into the annuity pricing, not a separate fee.

Find out what your tax bill actually looks like before you sell, including the parts your CPA may not raise until the return is already being prepared.

Most people find out what they owe after the sale closes, when nothing can be changed. A short conversation now tells you the number, which layers apply to your situation, and which options are still open while the sale is still in front of you.

  • What you will actually owe: federal, the 3.8% surtax, recapture and your state
  • Which of those layers you can still do something about
  • Whether spreading the sale changes the number in your case
More details (optional)
Hans Goldstein, EA
Admitted to practice before the IRS

Hans Goldstein · 213-414-2808 · Hans Goldstein: Tax & Exit Planning · This is an educational conversation, not tax advice. Bring your CPA in before you file.

Hans Goldstein, a licensed insurance agent (CA Insurance License #4273294), will contact you and may discuss insurance products, including annuities.

Educational. Not tax or legal advice. Goldstein & Co. is not affiliated with or endorsed by Black Stone Minerals, Kimbell Royalty Partners, Brigham Minerals, Sitio Royalties, Viper Energy Partners, or PHX Minerals.

Run your specific numbers

The calculator runs your sale through real 2026 federal + state tax brackets and shows §453 savings vs lump sum side-by-side.

Run the calculator → 213-414-2808
Get my number Book 15 min Call

Hans Goldstein is an Enrolled Agent, admitted to practice before the Internal Revenue Service. Not affiliated with or endorsed by the IRS. General education, not tax or legal advice for your situation.