In April 2026, New York State and City leaders jointly proposed a new annual tax on city residential properties valued at $5 million and above whose owners maintain a primary residence elsewhere — commonly called a "pied-à-terre tax," and in much of the press a "billionaire tax." The proposal revived a familiar question: who owns the city's most expensive homes, and what might a tax like this mean for the luxury market?
It is a question that has been debated far more than it has been measured. "Pied-à-terre" — a second home, a part-time residence — describes how a property is used, not a category recorded in any deed or tracked by any commercial real estate platform. So at Howard Hanna NYC, we looked at the public record directly.
Key takeaway: Howard Hanna NYC analyzed more than 4,000 Manhattan residential deeds of $5 million or more recorded between 2021 and 2026. The share of these luxury sales fitting a non-resident buyer profile rose from about 68% to about 74% over the period, even as overall luxury sales held steady. The figures are a directional proxy drawn from public ACRIS records, not a verified count.
Photo by Rihards Gederts | Howard Hanna NYC
Our Approach
Drawing on New York City's public property records, we examined more than 4,000 residential sales of $5 million or more in Manhattan recorded between January 2021 and May 2026.
Because no record explicitly labels a property as a pied-à-terre, we developed a proxy to approximate non-resident ownership, built on signals available in the public deed record. Applied consistently across the full five-year period, it lets us track how the non-resident share of the luxury market has shifted over time.
We want to be clear about what this is and is not: it is a directional proxy, not a verified count of pied-à-terres. A property's ownership structure and the address on a deed are useful indicators, but they are not the same as a confirmed residency status — a point the City Comptroller's own review of the proposal also emphasized. We therefore read these figures as a directional measure of a trend, not a precise tally.
What the Data Shows
First, the luxury market has remained active. After softer years in 2023 and 2024, high-end closings recovered in 2025, and 2026 is pacing in line with that recovery. Through the first months of 2026, both dollar volume and median price are up modestly year-over-year against the same period in 2025 — the median sale price crossed $8 million for the first time in our five-year dataset.
Second, and more striking: the share of these luxury closings fitting a non-resident profile has risen over the period — from roughly 68% in 2021 to about 74% in early 2026 — though not in a straight line, dipping in 2022 and 2024 before reaching its high point. In broad terms, the non-resident segment makes up a larger share of high-end purchases today than it did five years ago.
A Note on International Buyers
One finding cuts against a common assumption. In the public conversation, "pied-à-terre" is often shorthand for foreign ownership. Yet only about 1% of the sales we examined showed a non-U.S. country in the buyer's address of record. That figure dramatically understates true international ownership — not because overseas buyers are absent, but because many purchase through U.S.-registered entities that list a domestic address on the deed. It is a useful reminder that the headline numbers in any single data field rarely tell the whole story.
Putting the Numbers in Context
The data does not argue for or against the proposed tax. What it does is add measurement to the debate. Revenue projections have ranged widely — the city projects roughly $500 million a year, while the City Comptroller's office estimated that, after accounting for rental exemptions and likely changes in owner behavior, collections could fall to between $340 million and $380 million. Such projections depend heavily on how the non-resident ownership base behaves over time. Our analysis speaks to one piece of that picture: the flow of new purchases fitting a non-resident profile has been a growing share of high-end activity, even as the absolute number of luxury transactions has moved within a relatively narrow band.
Whether the tax will change these patterns is too early to say. The proposal was announced in April 2026 and still requires State Legislature approval; any market response would appear in transactions that close later in 2026 and beyond — which is exactly why we intend to keep tracking it.
What We'll Track Next : This is the first installment in what we intend as a quarterly series. We invite you to follow along.
Frequently Asked Questions
- What is the NYC pied-à-terre tax? The NYC pied-à-terre tax is a newly enacted five-year annual surcharge on certain New York City residential properties that are not used as the owner's primary residence. The tax takes effect for the fiscal year beginning July 1, 2026. The surcharge is calculated based on the property's value and applicable tax rate established under the legislation. The NYC Department of Finance is responsible for identifying covered properties and notifying property owners. Affected owners will be notified by August 30, 2026, and will have the opportunity to contest their classification if they believe their property should be excluded.
- Who could be affected by the pied-à-terre tax? The tax generally targets high-value residential properties valued at $5 million or more that are not the owner's primary residence. This may include luxury condominiums, co-ops, townhouses, and one-to-four-family homes used as second homes or investment properties. Primary residences are generally exempt. Ownership structures, occupancy arrangements, and future Department of Finance guidance may affect eligibility in specific cases.
- How much revenue would the pied-à-terre tax raise? New York City projects roughly $500 million a year. The NYC Comptroller's office estimated that, after accounting for rental exemptions and changes in owner behavior, actual collections could fall to between $340 million and $380 million.
- Is Manhattan's luxury market slowing because of the proposed tax? Not according to the data available. Howard Hanna NYC's analysis of public deed records shows $5 million-plus closings recovered in 2025 and 2026 is pacing similarly, with the median price crossing $8 million. Because closings lag signed contracts, any market response to the April 2026 proposal would appear in later-2026 data.
- How many Manhattan luxury buyers are non-residents? Using a directional proxy based on public deed records, the non-resident share of $5 million-plus Manhattan closings rose from about 68% in 2021 to about 74% in early 2026. This is an approximation, not a verified count.
Sources
- Transaction data — New York City Department of Finance, ACRIS, via NYC Open Data. Figures reflect Howard Hanna NYC's own analysis of Manhattan residential deeds of $5 million or more recorded January 2021–May 2026. data.cityofnewyork.us
- Tax proposal and $500M projection — Office of Governor Kathy Hochul, press release, April 15, 2026.
- Tax scope and primary-residence exclusion — Office of the Mayor of New York City, press release, April 15, 2026.
- Revenue revision ($340–380M) — Office of the New York City Comptroller, "The Pied-à-Terre Tax and Its Potential Revenues," April 2026. comptroller.nyc.gov
Important disclaimer: This article is provided for general informational and educational purposes only. It does not constitute, and should not be relied upon as, tax advice, legal advice, investment advice, financial advice, or accounting advice of any kind, nor is it a recommendation to buy, sell, or hold any property or security. Howard Hanna NYC is a licensed real estate brokerage and is not a law firm, accounting firm, tax advisor, or registered investment adviser. The proposed pied-à-terre tax described here had not been enacted as of the date of writing and remained subject to legislative approval; its scope, rates, exemptions, and effective date may change. Any decision regarding real estate, taxes, or investments should be made only after consulting a qualified attorney, tax professional, or financial advisor regarding your specific circumstances.
About the data: Figures are derived from public property records and reflect a methodological proxy for non-resident ownership based on signals such as ownership structure and the buyer's address of record. The proxy is not a verified determination of any property's use or any owner's residency, and classifications for individual transactions may be inaccurate. Co-op transfers are underrepresented in the public record and may not be fully captured.
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