Wealthy Transplants Must Prove That Their Hearts—Not Just Their Wallets—Are in Florida

In this 2023 article, Tax partner Judson Stein spoke with Town and Country Magazine about the wave of New York–to–Florida transplants, with the transplants having the expectation that they will no longer be subjected to New York income taxation. Contrary to what many believe, this involves more than counting the number of days one is outside of New York. One must actually establish the new domicile. Because the New York State Department of Taxation and Finance can’t read minds, they look for evidence that New York has been abandoned as one’s domicile and that it has been established somewhere else. Transplants must prove that their hearts and minds have truly made the transition. And, these issues are not unique to New York.