Last week, Gov. Hochul proposed a tax on high-value second homes, known as pied-à-terres, stating it would raise $500 million a year for New York City.
As a former New York City finance commissioner, I’ve seen firsthand how difficult it is to administer the city’s already complex property tax system. Adding yet another layer — through a pied-à-terre tax — will not deliver the promised revenue and will be difficult to administer fairly.
Estimates of the revenue from a pied-à-terre tax have varied significantly and have generally declined as the analyses have improved. The Fiscal Policy Institute once projected as much as $650 million. The NYC Independent Budget Office estimated $390 million annually, later revising that figure down to $232 million. In 2023, city Comptroller Brad Lander projected between $239 million and $277 million.
A reasonable expectation is closer to $140 million to $280 million annually. That gap is not marginal — it is the difference between a headline and a realistic policy. There is little evidence that a stable base exists to support a $500 million annual tax.
These differences reflect uncertainty about the size of the tax base, the challenges of administering the tax, and how buyers and sellers will respond.
First, the city does not have a clear or reliable way to identify second homes. Many high-value properties are held through LLCs or trusts, but ownership structure does not determine whether a unit is a primary residence. Any effort to do so would require new rules, new data, and ongoing administrative judgments. The problem is not just defining a second home — but proving it, consistently and at scale. If the definition is unclear or difficult to verify, enforcement will be inconsistent, and the tax could be applied to unintended targets.
The proposal also runs into challenges with how the city values property. Assessed value is not the same as market value. Co-ops and condos are valued as income-producing properties like rentals, not based on actual sales prices. As a result, assessed values often differ widely from what properties would sell for. Prior analysis shows that a narrow band of assessed values can correspond to market prices ranging from under $1 million to nearly $9 million.
In other words, properties that look identical to the tax system can be worlds apart in reality, making precise targeting unreliable and results uneven. These challenges are not theoretical. The city’s methodology for valuing co-ops and condos is currently under judicial review in pending litigation, underscoring how unsettled these issues remain.
It would also strain an already complex system. City property tax assessments are government-determined and frequently challenged. A new tax tied to those valuations would increase disputes over both value and eligibility. That means more appeals, greater administrative burden, and higher legal costs — costs that reduce net revenue and make the tax harder to administer effectively.
Even if those issues could be addressed, the tax base would not remain fixed. Tax policy influences behavior, particularly in markets where capital is mobile. A tax on second homes will change how property is owned and used. Some owners will restructure. Some will delay or forgo purchases. Some investments will move elsewhere. The exact scale of these responses is uncertain. The direction is not. In a market as mobile as high-end real estate, even modest shifts can erode the tax base.
The city’s property tax foundation already has significant structural challenges. The pied-à-terre tax is aimed at raising revenue and targeting high-value second homes, but layered onto that foundation, it risks delivering neither.
Stark is the former finance commissioner of New York City.