§453 · Sell Mobile Home Park Texas

Selling Your Mobile Home Park in Texas — Defer the Capital Gain

If you're selling a mobile home park in Texas, the tax math depends heavily on your state's capital-gains treatment. Texas's top LTCG rate is 0% — combined with federal 23.8% (20% LTCG + 3.8% NIIT), a lump-sum sale gives back 23.8% of your gain in year one. IRC §453 structured installment sale spreads the gain across the payment schedule, keeping you in lower brackets each year.

§453 Mechanic — How the Money Flows

Buyer cash → Assignment Co. → A-rated carrier → You, on schedule

BUYER pays full cash at closing ASSIGNMENT CO. qualified entity, regulated purchases annuity A-RATED CARRIER Pacific Life · MetLife Independent Life · USAA SELLER (you) paid on chosen 5-30 yr schedule Closing day — one wire, one assignment Gain recognized proportionally each year per IRC §453 (Treas. Reg. §15A.453-1)

This page covers the mobile home park sale in Texas specifically. For the general framework see the mobile home park guide or the §453 SIS basics.

The math — $8M sale, 20-year hold, Texas resident

ApproachEffective tax rateTax bill
Lump sum23.8%~$3.04M (38%)
10-year §45317%~$2.18M (27%)

The §453 spread captures roughly the difference between these two numbers — typically 8-12 percentage points of the gain depending on your specific deal economics and Texas's bracket structure.

Texas-specific tax wrinkle

Texas has no state income tax, but federal LTCG + NIIT still apply. §453 still keeps you in lower federal brackets per year and preserves other deductions.

The Texas mobile home park market

Texas has ~1,800 parks and no statewide rent control — a major valuation premium versus California. Sun Communities, RHP, and Yes! Communities are active in Houston/DFW; the Permian basin (Midland-Odessa) has unique demand from energy-worker housing that drove cap rates to 5-6% in 2022-2023. Many TX parks are RV/MH hybrid, which complicates the §1250 vs §1245 allocation at sale — the RV portion may be inventory-character. No state income tax means §453's federal-bracket-smoothing is the entire benefit.

Texas buyers and consolidators

The active acquirers buying mobile home parks in Texas: Sun Communities (NYSE: SUI), Equity LifeStyle Properties (ELS), RHP Properties, Roberts Resorts, Yes! Communities, Inspire Communities. These institutional buyers' M&A counsel are familiar with the §453 mechanic — papering the assignment at closing is standard.

Mobile Home Park-specific §453 wrinkle (applies in every state)

§1250 unrecaptured depreciation on the long-hold property spreads under §453; §1245 recapture on park-owned homes (POH) and utility infrastructure equipment is year-one.

When this fits a Texas seller

  • $1.5M+ sale price (carrier minimums on the §453-deferred portion)
  • Long hold with meaningful gain (where Texas's 0% state rate stacks on federal)
  • Sophisticated buyer whose counsel will paper the §453 assignment
  • Texas resident at closing (state residency matters for the state-tax piece)

How I work

Hans Goldstein, IRC §453 specialist. I place §453 structured installment sales through carrier-appointed brokerage relationships with Pacific Life, MetLife, Independent Life, and USAA Life — all four licensed in all 50 states including Texas.

Free 15-minute fit-check call. Bring your Texas sale details (price, basis, prior depreciation if applicable, closing timeline) — I model lump-sum vs §453 against your actual numbers.

Frequently asked

Q: I'm a Texas resident but the property is in another state. Where's the tax? A: Generally the gain is sourced to where the property sits (real estate) or where the seller resides (intangibles). Talk to your CPA on multi-state allocation; §453 mechanic works the same.

Q: I'm planning to move out of Texas before closing. Does that change anything? A: Maybe. Texas's residency tests differ — California's exit tests are aggressive; other states less so. Talk to a state-tax specialist before timing the move.

Q: Does the §453 mechanic differ state-to-state? A: No. §453 is federal. State tax rates determine the size of the savings; the mechanic is identical.

Hans Goldstein, NPN 20602398

📄 Get the §453 Quick Reference PDF + free fit-check

4-page reference card on the §453 SIS mechanic, when it fits, §453-vs-DST comparison, and state-by-state math. Built for sellers and CPAs.

Drop your info — instant PDF download + within 1 business day Hans will email a preliminary read on which structure fits your deal. No retainer. Carrier compensates the broker — not you.

I agree to receive calls and texts from Hans Goldstein at the number provided. Msg/data rates apply. Reply STOP to opt out.

📞 Hans Goldstein · 213-726-0518 · CA Insurance License #4322192 · Independent §453 specialist · Goldstein & Co. LLC

Educational. Not tax or legal advice. Texas tax treatment of §453 generally follows federal — confirm with your CPA.

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 → 213-726-0518