Constructing public rent: Property tax appeals and the fiscal strategies of rentier capitalism

Abstract

This research analyzes the fiscal strategies real estate investors use to shift public funds onto private balance sheets, a process I frame as constructing public rent. Leveraging a novel dataset that links ownership with property tax appeal filings, I use a mixed-methods approach that combines qualitative fieldwork—attending valuation and tax assessment conferences—with a computational analysis of property ownership and appeal filings in Memphis, Tennessee, between 2021 and 2023. My findings show that institutional single-family rental investors (12.5%) are nearly three times as likely to file property tax appeals when compared to other single-family investors (4.3%) and six times as likely when compared to homeowners (2.2%). This broader pattern is also evident as ownership concentrates at the neighborhood level, increasing the likelihood that investors pursue appeals in areas where their market share is highest, such as build-to-rent and corporate owned neighborhoods. The paper identifies build-to-rent developments as particularly concerning, as the sub-market concentration of ownership in these developments may limit the supply of transactions data necessary for a “mass appraisal” of real estate, potentially requiring assessment staff to adopt manual appraisal methods that could leave cities more vulnerable to property tax appeals.