Federal FIRPTA at 15% applies on every U.S. foreign-seller closing. State-level withholding stacks on top in some states — not others. Below, every U.S. state organized by what actually happens at the closing table.
These states collect a state-level withholding at the closing table, in addition to federal FIRPTA. The rate and form differ per state; each state has its own reduction-certificate path (analogous to a federal Form 8288-B).
The cleanest U.S. states for foreign-seller exits. Federal FIRPTA at 15% is the entire state-plus-federal exposure — no state withholding at closing, no state return obligation on the gain.
The middle bucket. Closing-table cash flow is federal FIRPTA only, but the foreign seller still owes state income tax on the gain via that state's nonresident return the following year. This is a common source of seller surprise; we brief every client on the state-return timing before closing.
North Carolina is the only state in this bucket. The buyer files Form NC-1099NRS with NCDOR within 15 days of closing — an information return that reports the foreign seller's name, taxpayer ID, sale price, and closing date. The seller then files Form D-400 the following year and pays NC income tax on the gain.
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