#LegalBytes: The Official Podcast of Cummings & Cummings Law

Attorney and CPA Chad D. Cummings notes the Financial Times report that California billionaires have put nearly forty million dollars into the campaign against Proposition 40, the wealth tax on the November ballot. The measure would impose a one-time five percent tax on the net worth of Californians holding more than one billion dollars in covered assets. The opposition committee Building a Better California received multi-million-dollar checks from technology and venture investors, according to an August 14 filing. These are people writing eight-figure checks for the chance that a tax might not pass. Most business owners do not have that option and do not need it. Changing where a company is domiciled and where the owner resides can alter tax exposure without a ballot campaign or a lobby in Sacramento. Florida and Texas impose no personal income tax and no wealth tax. Neither is debating one. The rules are knowable in advance. California’s recurring ballot fights create uncertainty that never appears on a rate table. The people spending forty million dollars this fall have too much fixed in the state to walk away. Most business owners are not in that position and can decide where their company lives long before anyone counts the ballots. Learn about transferring your company out of California: https://www.cummings.law/redomestication/move-business-out-of-california

Attorney and CPA Chad D. Cummings examines the July 2026 exchange between Tennessee and Paramount Skydance. On July 2, Deputy Governor Stuart McWhorter invited the studio to move its headquarters to Tennessee, citing fiscal discipline, low taxes, and predictable governance. Days later, California Attorney General Rob Bonta led a twelve-state coalition seeking to block Paramount’s roughly $110 billion acquisition of Warner Bros. Discovery—after the Justice Department had already cleared the deal. Paramount responded by opening exploratory talks with Tennessee, Texas, and Georgia. Roughly 30,000 jobs and an estimated $500 million in annual tax savings are at stake. Bonta called the possibility of departure blackmail. Choosing a domicile is the ordinary right of every business, not coercion. Tennessee competed for the company. Florida and Texas operate on the same premise: no personal income tax and the assumption that a business chooses to be there and can choose otherwise. Learn about moving your company out of California: https://www.cummings.law/redomestication/move-business-out-of-california

Attorney and CPA Chad D. Cummings reviews Proposition 40, the California Billionaire Tax Act on the November 3, 2026 ballot. The measure imposes a one-time five percent tax on the net worth of billionaires who resided in California as of January 1, 2026, measured as of December 31, 2026. A Tax Foundation analysis by Jared Walczak concludes the measure is vulnerable to constitutional challenge on so many independent grounds that courts may strike it down entirely. The residency date precedes the election by more than ten months, so a person who left on January 2 still owes tax on worldwide wealth at year-end, including assets accumulated elsewhere. The measure claims apportionment without any reduction based on residency history. A nonresident spouse’s out-of-state wealth can be attributed to the California spouse, trusts funded by a California billionaire are captured even when all parties and assets sit elsewhere, and divorce debts are added back. Appraisers face uncapped penalties of up to four percent of any understatement. If courts invalidate the tax, California still faces the departure of founders, the deterrence of future ones, years of litigation, and zero collections. Florida and Texas have no personal income tax and no wealth tax. Neither attempts to tax people who already left or to reach spouses and assets outside their borders. Learn more about moving your California LLC or corporation to another state: https://www.cummings.law/redomestication/move-business-out-of-california

Attorney and CPA Chad D. Cummings examines New York’s new Pied-à-Terre Tax. Signed by Governor Kathy Hochul on May 28, 2026 and effective July 1, the law imposes an annual surcharge on New York City residential property that is not the owner’s primary residence and has a market value above five million dollars. Occupancy of 183 days or fewer triggers it, and cooperative shares are treated as real property. The state projects five hundred million dollars in revenue. The tax targets former residents who kept a foothold in the city rather than current residents. The Department of Finance released a tax roll covering more than nine hundred thousand properties; a Staten Island court temporarily halted the rollout on August 10 after incorrect primary-residence flags, with roughly seventeen thousand notices already issued. Cooperative valuations rely on opaque share-allocation arithmetic. Florida and Texas impose no personal income tax and no comparable second-home surcharge. Property is fixed and cannot be moved. A company can be. Anyone who has received a notice should consult counsel and assemble residency and occupancy records before responding. Learn about transferring your company out of New York: https://www.cummings.law/redomestication/move-business-out-of-new-york/

Attorney and CPA Chad D. Cummings notes that consulting practices are among the easiest businesses to relocate and among the most likely to remain stuck in the wrong state. A consulting firm has no factory or storefront; its assets are a laptop, a methodology, and a client list. Yet many consultants still file annual reports and pay fees in a state they left years ago. California imposes an $800 minimum franchise tax on an LLC that earned nothing, plus gross-receipts fees above certain thresholds. New York requires costly newspaper publication for new LLCs and biennial filing fees. Illinois and New Jersey tax the income that passes through to the owner. Florida and Texas impose no personal income tax. Because most consulting practices are single-member LLCs or S corporations, that income lands directly on the owner’s personal return. Tax Foundation data shows the average business relocating to a no-income-tax state retains more than $12,500 each year. Florida and Texas also maintain strong asset-protection statutes and predictable business law, valuable when the product is advice that can later be second-guessed. Redomestication moves the existing entity so the federal employer identification number, engagement letters, banking relationships, and professional liability coverage all continue without interruption. Owners need not live in the destination state; a commercial registered agent satisfies the street-address requirement. Personal tax residency remains a separate question for counsel and a tax professional and should be resolved before any filing. Learn more about moving your consulting practice to a new state: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings addresses the digital nomad whose company is still stuck in the wrong state. You work from a laptop in Lisbon, Mexico City, or Chiang Mai. Clients pay in dollars through Stripe, and nothing about how you earn requires a fixed location. Yet the LLC or corporation you formed years ago still has a domicile that demands franchise fees, annual reports, and in some cases a claim on income earned thousands of miles away. California imposes an $800 minimum franchise tax even on an LLC that earns nothing and has a long record of pursuing former residents. New York applies similar persistence. Redomestication moves the company you already have. The federal employer identification number stays the same, so your Stripe account, business banking, merchant processing, and client contracts remain intact. Dissolving and reforming severs all of it. Florida and Texas impose no personal income tax. For a single-member LLC or S corporation, business income flows to your personal return, and neither state cares that you spend most of the year abroad. Neither imposes California’s minimum franchise tax. A commercial registered agent satisfies the street-address requirement; owners and members are not required to live there. Personal tax residency remains a separate question for counsel and a tax professional. Your work stopped being tied to a location. Your company can stop being tied to the wrong one. Learn about redomesticating your company to a new state: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings explains why owner-operators should never dissolve their company when leaving a high-tax state. The DOT number, MC authority, safety record, insurance rate, and factoring relationship all sit on one legal entity. Dissolving it ends the FEIN, the Form 2290 history, and the operating record, forcing a new DOT number, a new entrant audit, and an empty CSA profile that underwriters and brokers treat as zero history. Redomestication moves the home state of the existing company so the entity, identification number, authority, and contracts all survive. Florida and Texas impose no personal income tax on the pass-through income that settles into a single-member LLC or S corporation. The average business relocating to a no-income-tax state retains more than $12,500 a year. California regulates trucks as a problem; Texas and Florida treat freight as essential. Moving the company is legal and does not require burning down what you spent years building. Learn more about moving your trucking company to a new state: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings notes a Financial Times report from New Zealand that reveals more about California than about the South Pacific. A private club is sending eight new golden-visa arrivals on a polar expedition into the Southern Alps. Applications under the program jumped from 115 over three years to more than 700 in the past fourteen months, with Americans filing 277 and Californians leading. The entry price is five million New Zealand dollars. One California fund manager who obtained a visa complained to the Prime Minister that spending more than 183 days a year would trigger tax on her worldwide earnings and warned that every dollar is mobile. Florida and Texas impose no personal income tax, require no minimum investment, and impose no day-count trap that converts global income into local tax liability. High-tax states assumed residents were captive. The capital kept moving. Learn more about redomesticating out of California: https://www.cummings.law/redomestication/move-business-out-of-california

Attorney and CPA Chad D. Cummings reviews the U.S. Census Bureau’s domestic migration data for 2025. California lost 229,100 residents to other states. New York lost 137,600. Illinois lost 40,000. New Jersey lost 37,400. Massachusetts lost 33,300. Those five states produced a combined outflow of 477,400 people in a single year. Visual Capitalist mapped the figures, and the pattern is clear: the country is sorting itself by tax policy. California ranks 48th on the Tax Foundation’s 2026 State Tax Competitiveness Index. New York ranks 50th. New Jersey ranks 49th. Massachusetts ranks 43rd. Illinois ranks in the bottom quarter. Four of the six lowest-ranked states for tax competitiveness sit among the five largest domestic losers. Learn about moving your company to another state: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings analyzes the July 26, 2026 sale of Steve Wynn’s Beverly Hills estate. Wynn purchased the 2.7-acre property in 2015 for $47.85 million, invested millions in renovations that expanded it to 27,000 square feet with 11 bedrooms and 14.5 bathrooms, listed it for $110 million in January 2021, and ultimately sold it for $47.75 million—$100,000 less than the original purchase price before any improvements. Listing agent Leonard Rabinowitz of Christie’s International Real Estate called the outcome disappointing and attributed it directly to California’s tax environment and the proposed billionaire tax, which have caused high-net-worth residents to leave the state and shrink the buyer pool. This is the second-order consequence of the exodus documented across this channel: when the potential buyers of $100 million homes relocate to Florida and Texas, sellers in Beverly Hills cannot clear previous price levels. The transaction stands as the highest-priced home sale in Beverly Hills for 2026, yet it closed below the 2015 acquisition cost. Larry Page, Sergey Brin, Mark Zuckerberg, Peter Thiel, Travis Kalanick, and David Sacks are among those who have shifted capital out of California. Miami is setting records while California’s ultra-luxury market softens. The state’s wealth tax measure, set for the November 3 ballot, would impose a five percent levy on billionaire assets and has already drawn statements that the threshold will not remain fixed at one billion. Combined with a 13.3 percent top income tax rate, an 8.84 percent corporate rate, and the nation’s highest state sales tax, California has become expensive to live in, operate in, and now sell in. The agent stated the buying pool is shrinking—in the present tense. Learn more about how to move your company out of California: https://www.cummings.law/redomestication/move-business-out-of-california

Attorney and CPA Chad D. Cummings examines the launch of the Texas Stock Exchange. The TXSE, based in Dallas and pronounced “Tex-ee,” went fully live on July 31, 2026 as the first new major U.S. stock exchange in decades. It has raised approximately $275 million from BlackRock, Goldman Sachs, JPMorgan Chase, Citadel Securities, Charles Schwab, and Jane Street Group. Corporate listings are expected in the fourth quarter of 2026, with the first IPOs planned for 2027. The same firms that built Wall Street are now funding the exchange that will compete with it. Governor Greg Abbott has called the Texas Stock Exchange the natural extension of a shift in the center of gravity for American capitalism toward the boom belt, a region now referred to as Y’all Street. Both the New York Stock Exchange and Nasdaq responded by opening their own Texas branches. Texas has spent the last two years assembling the full infrastructure: the Texas Business Court launched in September 2024, Senate Bill 29 codified the business judgment rule and other governance tools, and more than 25 companies representing over four trillion dollars in market value have committed to leaving Delaware for Texas since mid-2024. Dell, ExxonMobil, Tesla, SpaceX, and Samsung have already moved. Texas imposes no individual income tax and ranks 7th on the Tax Foundation’s 2026 State Tax Competitiveness Index. New York ranks 50th. The TXSE pitch centers on greater transparency, competitive pricing, and the pro-business orientation of the state. For companies considering transferring to Texas those factors now come with a stock exchange attached. Learn more: https://www.cummings.law/onboard/texas.html

Attorney and CPA Chad D. Cummings presents this provocative overview of Maryland’s 2025 tax legislation, which the Tax Foundation described as the most aggressive package of tax increases in the nation. The changes were made retroactive to January 1, 2025. Maryland ranks 46th on the Tax Foundation’s 2026 State Tax Competitiveness Index after falling past Washington. The individual income tax expanded to ten brackets with a new top state rate of 6.5 percent. County income tax caps rose to 3.3 percent, allowing combined state and local rates to reach 9.8 percent. A two percent capital gains surcharge on federal adjusted gross income above $350,000 produces a combined capital gains rate of 11.8 percent. Section 179 first-year expensing for pass-through businesses is capped at $25,000 against a federal allowance of one million dollars. The corporate rate is 8.25 percent and includes global intangible low-taxed income, converting to net CFC-tested income under recent federal law. A pending bill would raise the top individual rate to 7 percent and impose mandatory worldwide combined reporting, making Maryland the first state to require it. Maryland is the only state that imposes both an estate tax at 16 percent and an inheritance tax at 10 percent. It is also the only state that taxes digital advertising, digital services, and business-to-business technology transactions. Florida and Texas impose neither an estate tax nor an inheritance tax and have no individual income tax. Learn about transferring your company out of Maryland: https://www.cummings.law/redomestication/move-business-out-of-maryland/

Attorney and CPA Chad D. Cummings presents this timely presentation on the five features of Minnesota’s tax code that make the state uniquely expensive for business owners. Minnesota taxes long-term capital gains at a higher effective rate than ordinary income through a surtax that few business owners discover until the year they sell. The top individual income tax rate is 9.85 percent, the fifth highest in the country, so one million dollars of pass-through income generates a $98,500 state tax bill that would be zero in Florida or Texas. The corporate income tax rate is 9.8 percent, the second highest in the nation, and the state also imposes an alternative minimum tax plus inclusion of certain foreign subsidiary income. Minnesota is one of the few states that maintains an alternative minimum tax on individuals, requiring many taxpayers to calculate liability twice and pay the higher amount. The legislature is considering a one percent annual wealth tax on non-real assets exceeding ten million dollars. Minnesota also maintains a 16 percent top estate tax rate and a split-roll property tax that shifts more of the burden onto commercial property. Every one of Minnesota’s five neighbors offers a lower tax burden. South Dakota imposes no income tax. The most expensive state in its region is surrounded by states competing for its residents and businesses by cutting rates while Minnesota responds by proposing a wealth tax. Learn more about transfering your company out of Minnesota: https://www.cummings.law/redomestication/move-business-out-of-minnesota/

Attorney and CPA Chad D. Cummings presents this powerful presentation on New York’s shrinking share of the nation’s millionaires. The Citizen Budget Commission, a nonpartisan fiscal watchdog, found that New York’s share fell from 12.7 percent in 2010 to 8.7 percent in 2022, the steepest decline of any state. Had New York maintained its 2010 share, the state would have collected $10.7 billion more in personal income tax revenue in 2022 alone. The top one percent of earners pay approximately 45 percent of all state income taxes. When those earners leave, nearly half the income tax base leaves with them. Mayor Zohran Mamdani responded by filming a video outside Ken Griffin’s $238 million Manhattan penthouse announcing the pied-à-terre tax, projected to raise $500 million per year. The departures are costing $10.7 billion. The ratio is 21 to 1. For every dollar the new tax generates, the millionaire exodus removes twenty-one dollars from the state’s income tax base. New York has lost more residents to every other state than it has gained from any of them, with Florida and Texas as the top destinations. A taxpayer earning five million dollars in New York City owes approximately $700,000 in combined state and city income taxes. In Florida or Texas that figure is zero. Over ten years the difference is seven million dollars. The data show the cost of remaining has exceeded the cost of leaving. Learn more about transferring your company out of NYC: https://www.cummings.law/redomestication/move-business-out-of-new-york/

Attorney and CPA Chad D. Cummings presents this powerful presentation on New York City’s new pied-à-terre tax. The tax was sold as targeting 31,000 luxury second homes. Mayor Zohran Mamdani’s administration then published a searchable database containing more than 960,000 residences and individuals, complete with full names and addresses. The list includes modest homes in working-class neighborhoods of the Bronx and Staten Island. Council Minority Leader David Carr found his own home on the list and called the publication reckless. Author Alex Berenson reported that his 81-year-old mother, a full-time resident of her townhouse for 30 years, received a letter claiming she owed $56,000. City Hall projects $500 million in annual revenue while the City Comptroller projects $340 million to $380 million and declining collections as owners sell, dispute, or leave. The mayor announced the tax by filming a video outside Ken Griffin’s penthouse. New York ranks 50th on the Tax Foundation’s 2026 State Tax Competitiveness Index. The pattern is familiar: the tax is proposed as limited to the wealthiest, the threshold is set high, and the implementation expands dramatically. Redomestication is the legal process of transferring a company out of New York without dissolving it. When paired with a change of personal residency and a reduction of New York operations, it can reduce or eliminate state tax exposure for the entity and its owners. Learn more: https://www.cummings.law/redomestication/move-business-out-of-new-york/

Attorney and CPA Chad D. Cummings presents this powerful presentation on the five permanent consequences of dissolving an entity instead of redomesticating it. The federal employer identification number does not survive dissolution and a new entity receives a new FEIN with no filing history, no tax elections, and no administrative continuity. Contracts bind a dead entity, limited liability protection disappears, and known and unknown liabilities reach the owners personally. Bank accounts tied to the old FEIN are closed and must be rebuilt from zero, including merchant processing and credit relationships. Dissolution can trigger taxable gain recognition at both the entity and owner levels under the Internal Revenue Code, while properly structured redomestication is a non-taxable reorganization. Credit history, vendor terms, and years of credibility remain attached to the dissolved entity and do not transfer. Redomestication preserves the FEIN, the contracts, the bank accounts, the tax attributes, and the credit profile because the entity continues to exist. Every one of these consequences is permanent and every one of them is avoidable by instead redomesticating your company to a new state. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings presents this powerful presentation on the controlled experiment playing out between Seattle and Bellevue. Downtown Seattle lost 30,000 jobs after imposing the JumpStart payroll tax in 2020, while Bellevue ten miles across the lake imposed no such tax. The Downtown Seattle Association reported on June 15, 2026 that the result has been a slowdown, not a jump start. Downtown Seattle office values fell 48 percent from 2020 to 2025 while Bellevue’s rose 7 percent. Seattle’s central business district vacancy climbed from 6.7 percent to 32 percent. Amazon has grown from 450 employees in Bellevue to more than 15,000 and directed major housing and transportation investment there. Seattle collected hundreds of millions in payroll tax revenue and lost half the value of its office district. The same pattern appears at the state level, where Washington ranks 45th on the Tax Foundation’s 2026 State Tax Competitiveness Index and high-profile departures to Florida continue. Two cities, same labor market, same geography. One changed the tax. The results are in. Learn more about transferring a company out of Washington: https://www.cummings.law/redomestication/move-business-out-of-washington/

Attorney and CPA Chad D. Cummings presents this powerful presentation on the decision by Apollo Global Management to establish its second headquarters in Austin and explains how to move a company out of New York while keeping the EIN, contracts, and bank accounts intact. The firm manages approximately one trillion dollars in assets and has been based in New York for its entire history. CEO Marc Rowan evaluated Austin, Miami, Palm Beach, and Nashville before selecting Texas, where most future hiring will occur. New York ranks 50th on the Tax Foundation’s 2026 State Tax Competitiveness Index while Texas ranks 7th and imposes no individual income tax. The same decision calculus that applies to a firm with four thousand employees applies to a firm with four. Headquarters location and state of incorporation should be deliberate choices, not defaults. Learn more: https://www.cummings.law/redomestication/move-business-out-of-new-york/

Attorney and CPA Chad D. Cummings examines a new law review article that challenges the traditional assumptions about where a company should be incorporated in this presentation. Professor Carliss Chatman of SMU Dedman School of Law argues that the internal affairs doctrine, which made Delaware the default for generations, governs only a small share of a company’s actual legal exposure. Most disputes arise from environmental, employment, consumer, contract, and regulatory matters that are litigated where the company operates, not where it is chartered. The article also shows that reincorporation into Texas creates no new franchise tax that operations had not already produced and proposes a practical three-part test for the incorporation decision. This presentation explains why incorporation should be a deliberate choice rather than an inheritance, and how redomestication allows business owners to transfer their company’s legal domicile to Texas or Florida without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. Learn more: https://www.cummings.law/onboard/texas.html

Attorney and CPA Chad D. Cummings examines Exxon Mobil’s decision to redomesticate from New Jersey to Texas and the opposition it faced from major proxy advisory firms in this presentation. After 144 years of incorporation in New Jersey, Exxon asked shareholders to approve a move to Texas. Institutional Shareholder Services and Glass Lewis recommended against it, citing investor protections, even as both firms were engaged in litigation against the Texas Attorney General over a disclosure statute. Shareholders ultimately approved the relocation, joining Tesla, Dell Technologies, and other major companies that have already made the same move. This presentation shows how redomestication allows business owners of any size to move a business out of New Jersey without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. The choice of domicile belongs to the owners of the company. Learn more: https://www.cummings.law/redomestication/move-business-out-of-new-jersey/

Attorney and CPA Chad D. Cummings analyzes the latest IRS migration data and the accelerating wealth shift to no-income-tax states in this presentation. In 2023, Florida gained $21 billion in adjusted gross income from interstate moves, more than the next five states combined, while California lost $12 billion, the largest outflow of any state. Over the four-year period from 2019 to 2023, Florida gained $137 billion and California lost $91 billion. The states gaining wealth are those with no individual income tax, while the states losing wealth are those with the highest rates and the highest costs of doing business. This presentation shows how redomestication allows business owners to transfer their company’s legal domicile to a new state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in a state losing income and population, the IRS data confirm the direction and the urgency. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings examines the latest high-profile relocation from Washington to Florida in this presentation. Gabe Newell, the co-founder and CEO of Valve, purchased a $70.8 million waterfront estate in Manalapan, Florida, joining Jeff Bezos, Howard Schultz, and other Washington billionaires who have already left the state. Washington ranks 45th on the Tax Foundation’s 2026 State Tax Competitiveness Index after imposing a 9.9 percent capital gains tax and raising its estate tax to the highest rate in the country at 35 percent. Florida imposes no state personal income tax, no capital gains tax, and no estate tax. This presentation shows how redomestication allows business owners to transfer their company out of Washington state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in Washington, the pattern of departures and the state's response make the decision clear. Learn more: https://www.cummings.law/redomestication/move-business-out-of-washington/

Attorney and and CPA Chad D. Cummings examines Texas’s historic overtaking of California in Fortune 500 headquarters in this presentation. For the first time, Texas leads California 57 to 56 on the 2026 Fortune 500 list, a reversal driven by companies including ExxonMobil, Chevron, Samsung Electronics America, SpaceX, and X relocating their headquarters or legal incorporation to Texas. Texas corporations now generate more revenue as well, and the gap is expected to widen as California’s high-tax environment and proposed wealth tax continue to drive capital and talent out of the state. California ranks 48th on the Tax Foundation’s 2026 State Tax Competitiveness Index with a 13.3 percent top individual income tax rate, while Texas ranks 7th and imposes no individual income tax. This presentation shows how redomestication allows business owners to transfer their company’s legal domicile out of California without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business still domiciled in California or another high-tax state, the direction of headquarters migration is clear. Learn more: https://www.cummings.law/redomestication/move-business-out-of-california/

Attorney and CPA Chad D. Cummings examines the Chicago Bears’ decision to leave Illinois after 106 years in this presentation. The franchise’s Board of Directors voted to pursue a new stadium in Hammond, Indiana, after years of failed negotiations with Illinois over public funding, while Indiana passed a funding bill in less than 60 days. Illinois ranks 38th on the Tax Foundation’s 2026 State Tax Competitiveness Index with the third-highest corporate tax rate in the country, the highest property taxes in the nation, a pension system funded at only 52 percent, and a proposed constitutional surtax that would raise the top individual rate to 7.95 percent. Indiana ranks 10th with significantly lower rates and a more competitive environment. This presentation shows how the same competitive dynamics driving the Bears, Samsung, Dell, ExxonMobil, and Tesla out of high-tax states apply to every business owner, and how redomestication allows Illinois companies to transfer to another state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If the Bears could not justify remaining in Illinois, the question for every other Illinois business owner is what is keeping you. Learn more: https://www.cummings.law/redomestication/move-business-out-of-illinois/

Attorney and CPA Chad D. Cummings examines the nationwide push for state wealth taxes and the clear lessons from Europe in this presentation. Tax Foundation president and CEO Daniel Bunn’s recent op-ed in The Hill surveys the growing movement across California, Washington, Rhode Island, Virginia, Michigan, and other states, concluding that these taxes will fail for the same reasons they failed abroad. Of the twelve OECD countries that imposed wealth taxes in 1996, nine have repealed them after capital flight, administrative complexity, and far lower revenue than projected. This presentation explains why the behavioral response at the state level will be even faster, how California’s Proposition 40 and similar measures already signal expanding thresholds and permanent taxation, and how redomestication allows business owners to transfer their company’s legal domicile to a new state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in a state pursuing these measures, the window to act is before they pass. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses Samsung Electronics' rapid relocation from New Jersey to Texas in this presentation. Eight months after opening a new 270,000 square foot headquarters in New Jersey, Samsung announced it is moving its U.S. headquarters and 1,000 corporate jobs to its campus in Plano, Texas. Samsung joins other major companies like Mercedes-Benz, Hertz, and ExxonMobil in choosing Texas over New Jersey, where the corporate tax rate reaches 11.5 percent. This presentation examines the growing corporate migration to Texas and how the same redomestication process Samsung effectively used for its operations is available to small and mid-sized businesses. Redomestication transfers the company to a new state without dissolution and without federal income tax consequences when performed correctly, preserving the FEIN, contracts, credit history, and bank accounts. If you own a business in a high-tax state like New Jersey, the math that Samsung performed is instructive. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses the upcoming California wealth tax ballot measure in this presentation as reported by Stephen Foley of the Financial Times. Proposition 40, which would impose a five percent tax on the net worth of California billionaires, has qualified for the November 3, 2026 general election and is shaping up as one of the most expensive and closely watched referendum battles in the state’s history. Backers argue it will raise $100 billion to replace lost federal healthcare funding, while opponents, including a broad coalition of billionaires, unions, and Governor Newsom, warn of capital flight, economic damage, and the likelihood that the tax will not remain limited to billionaires. This presentation examines the proposal’s details, the early exodus of high-net-worth individuals, the spoiler measures on the ballot, and the strategic implications for California business owners. Redomestication offers a proven path to transfer a company out of California without dissolution and without federal income tax consequences when performed correctly. If you own a business in California, the stakes of this vote are significant. Learn more: https://www.cummings.law/redomestication/move-business-out-of-california/

Attorney and CPA Chad D. Cummings discusses the aggressive residency audits by the California Franchise Tax Board in this presentation. Following the qualification of the California Billionaire Tax Act for the November 2026 ballot, the FTB has launched some of the most intrusive audits in its history, demanding GPS records, transaction data, and other evidence from departing high-net-worth individuals. This enforcement posture applies not only to individuals but to every business entity still domiciled in California, regardless of size. If your LLC or corporation remains formed in California, the FTB retains jurisdiction even if you personally relocated. This presentation explains how redomestication allows business owners to transfer their company out of California without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business still domiciled in California, the current audit activity and budget pressures make the timing urgent. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses the impact of major liquidity events on California business owners and the accelerating exodus to Florida in this presentation. SpaceX’s June 12, 2026 IPO at a valuation exceeding two trillion dollars created approximately 4,400 new millionaires in California, where the top marginal income tax rate is 13.3 percent. For an employee receiving ten million dollars in equity, that means a California tax bill of $1.33 million compared to zero in Florida. Similar events at companies like OpenAI are generating another wave of newly liquid California residents who have one opportunity to establish residency in a no-income-tax state before their gains are taxed. Brokers in South Florida report a surge of California area codes, and the pattern is clear: the people leaving are not retiring. They are founding companies, hiring employees, and deploying capital. This presentation explains how redomestication allows business owners to transfer their company’s legal domicile out of California without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in California, the math and the timing make the decision urgent. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings analyzes recent U.S. GDP growth data and the migration patterns driving it in this presentation. In 2025, the national economy grew 2.1 percent in real terms, with every state expanding. Florida led at 3.1 percent, Texas at 2.5 percent, and the Sun Belt outperformed the national average while high-tax states like California and New York showed slower underlying momentum when viewed alongside continued population loss. IRS migration data confirm that the states gaining residents and growing above the national average are those with no income tax and lower costs of doing business. This presentation shows how redomestication allows business owners to transfer their company’s legal domicile to Florida or Texas without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in a state losing population while relying on concentrated sector performance, the formula is clear. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses the accelerating trend of companies redomesticating from Delaware to Texas in this presentation. In June 2024, Tesla and SpaceX led the way. By June 2026, the movement has expanded significantly, with eight additional companies, including Dell Technologies, voting to redomesticate in a single month, representing a combined market value of approximately $290 billion. Since June 2024, more than 25 companies with over four trillion dollars in aggregate market value have committed to the move. This presentation examines the governance and tax advantages of Texas, the statutory conversion process used by these large corporations, and how the same redomestication mechanism is available to small and mid-sized businesses. Redomestication transfers the entity to a new state without dissolution and without federal income tax consequences when performed correctly, preserving the FEIN, contracts, credit history, and bank accounts. If you own a business still domiciled in Delaware or another high-tax state, the pattern is clear. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings reviews the California wealth tax ballot measure and the recent cease-and-desist letters sent by its authors to a critic. We discuss how the proposal, marketed as a one-time tax on billionaires, has already driven departures of significant wealth and income tax revenue, and how the authors have responded to criticism with legal threats rather than substantive debate. We also cover the broader implications for California business owners, including the risk of expanding wealth taxes and the importance of redomestication as a strategic tool to protect your company. Redomestication transfers your entity’s domicile to another state without dissolution and without federal income tax consequences when performed correctly, preserving your FEIN, contracts, credit history, and bank accounts. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses the qualified California Billionaire Tax Act ballot measure in this presentation. The measure, which would impose a five percent wealth tax on billionaires’ assets, has officially qualified for the November 3, 2026 general election despite opposition from Governor Newsom, Planned Parenthood Affiliates of California, the California Teachers Association, and others. Even before a single vote, the proposal has already driven significant departures, with billionaires such as Mark Zuckerberg, Larry Page, Sergey Brin, Peter Thiel, and David Sacks relocating out of state and costing California substantial ongoing income tax revenue at the 13.3 percent top marginal rate. This presentation explains how redomestication, paired with a change of personal residency and reduction of business operations in California, allows business owners to protect their companies from these expanding tax risks. The process transfers the entity’s domicile without dissolution and without federal income tax consequences when done properly. If you own a business in California, the pattern is clear. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings analyzes the lessons from Europe and the risks of California’s proposed wealth tax in this presentation. Of the twelve industrialized countries that imposed wealth taxes in 1990, nine repealed them by 2025 because the taxes proved difficult to administer, drove wealthy residents away, and generated far less revenue than projected. France lost an estimated 200 billion euros over two decades and repealed its wealth tax in 2018. Stanford economists Joshua Rauh and Benjamin Jaros applied that experience to California’s ballot measure and estimated it would raise only about $40 billion—not the $100 billion claimed—with 30 percent of the targeted billionaire wealth base already having left before the residency deadline. The federal proposal has already dropped the threshold from one billion to fifty million dollars and includes a 40 percent exit tax. This presentation explains how redomestication, paired with a change of personal residency and reduction of business operations in California, allows business owners to move their companies out of California. The process transfers the entity’s domicile without dissolution and without federal income tax consequences when done properly. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses the rapid expansion of wealth tax proposals targeting California business owners in this presentation. What began as a ballot measure marketed as a five percent tax on billionaires has already broadened, with federal proposals now aiming at net worth above fifty million dollars and a 40 percent exit tax for those who leave. California’s aggressive residency audits through the Franchise Tax Board, combined with the pattern seen in other jurisdictions where thresholds creep lower over time, make the risk immediate. Florida and Texas impose no state personal income tax and no wealth tax. This presentation explains how redomestication allows business owners to transfer their company’s legal domicile to a new state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in California, the direction of these proposals makes clear why now is the time to act. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings explains the strategic benefits of timely filing an Section 83(b) election in this presentation. By filing within 30 days of receiving property subject to a substantial risk of forfeiture, you lock in ordinary income recognition at the grant-date fair market value rather than at each vesting date, convert future appreciation into capital gain, start the capital gains holding period immediately, eliminate uncertainty around future tax rates and vesting events, and simplify the treatment of LLC or partnership interests. These advantages can deliver substantial tax savings when the property’s value at grant is low relative to its expected future value, but the election is irrevocable, carries risk if the property is forfeited, and must be filed correctly with no extensions. This presentation covers when the election makes sense, the mechanics, common pitfalls, and why professional guidance is essential. Learn more: https://www.cummings.law/onboard/83b/index.html

Attorney and CPA Chad D. Cummings explains how to file an Section 83(b) election in this presentation. Under Section 83(b) of the Internal Revenue Code, a person who receives property in connection with the performance of services that is subject to a substantial risk of forfeiture can elect to recognize the fair market value as income at the time of receipt rather than at each vesting date. This election accelerates the taxable event but can convert future appreciation from ordinary income to capital gains, delivering substantial tax savings when the property’s value at grant is low relative to its expected future value, such as with early-stage founder stock. However, the election is irrevocable, must be filed with the IRS within 30 calendar days of the transfer with no extensions, and carries real risk if the property is later forfeited or declines in value. This presentation covers when the election makes strategic sense, the interaction with state taxes, common pitfalls, and why professional guidance from a licensed attorney and CPA is essential before filing. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses Dell Technologies' decision to redomesticate from Delaware to Texas in this presentation. On May 4, 2026, Dell's Board of Directors unanimously approved the move, with a stockholder vote scheduled for June 25. Dell joins Tesla, ExxonMobil, TripAdvisor, Dropbox, and Pershing Square in leaving Delaware for Texas. The company, founded in a University of Texas dorm room, maintains its global headquarters in Round Rock and its largest domestic workforce in Texas. This redomestication aligns the legal domicile with operational reality without dissolving the entity, without creating a new company, and without triggering federal income tax. The company retains its FEIN, contracts, credit history, and NYSE listing. The same redomestication process our firm has successfully completed for over five hundred companies works for businesses of any size. If a Fortune 50 company is making this change, the question for every business owner still domiciled in a high-tax state is what you are waiting for. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings explains why Wyoming ranks first on the Tax Foundation’s 2026 State Tax Competitiveness Index in this presentation. The state imposes no individual income tax, no corporate income tax, no estate tax, and no inheritance tax, with low sales and property tax burdens. However, Wyoming’s revenue model depends heavily on severance taxes from oil, gas, and coal, creating volatility, and it maintains an uncapped capital stock tax on business net worth. Florida and Texas offer the same zero-income-tax advantage with more diversified economies and larger markets. This presentation shows how redomestication allows business owners to transfer their company’s legal domicile to or from Wyoming without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business considering Wyoming or need to move an existing Wyoming entity, this is the right way to do it. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings examines Wisconsin’s mixed tax competitiveness in this presentation. The state ranks 21st on the Tax Foundation’s 2026 State Tax Competitiveness Index with strong sales and property tax components, a uniform property tax system, no estate tax, and an overfunded pension system at 102 percent. However, Wisconsin maintains a high top individual income tax rate of 7.65 percent that the legislature has not reduced and a 7.9 percent corporate rate with a throwback rule and limited expensing. These weaknesses offset the stronger elements of the tax code. Florida and Texas impose no state personal income tax and offer far more competitive environments overall. This presentation shows how redomestication allows Wisconsin business owners to transfer their company to another state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in Wisconsin, the good parts of the tax code cannot fully offset the high income and corporate rates. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings examines West Virginia’s tax position in this presentation. The state ranks 32nd on the Tax Foundation’s 2026 State Tax Competitiveness Index with a top individual income tax rate of 4.82 percent and a corporate rate of 6.5 percent. While West Virginia has reduced rates and maintains a fully funded pension system, it carries one of the highest per capita debt loads in the country at $13,160, relies heavily on volatile energy extraction revenue, and imposes local gross receipts taxes that add variable burdens. Florida and Texas impose no state personal income tax and offer more stable, competitive environments. This presentation shows how redomestication allows West Virginia business owners to transfer their company to a new state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in West Virginia, the combination of high debt, commodity-dependent revenue, and ongoing tax burdens makes a compelling case for action. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings explains Washington’s declining tax competitiveness in this presentation. The state ranks 45th on the Tax Foundation’s 2026 State Tax Competitiveness Index after imposing a 9.9 percent capital gains tax, maintaining a multiple-rate Business and Occupation gross receipts tax that applies to revenue regardless of profit, raising its estate tax to the highest rate in the country at 35 percent, and layering additional taxes on digital services and advertising. These changes have erased Washington’s former advantage as a no-income-tax state and created one of the most burdensome tax environments for businesses and high earners. Florida and Texas impose no state personal income tax, no capital gains tax, and no estate tax. This presentation shows how redomestication allows Washington business owners to transfer their company out of Washington State without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in Washington, the policy direction and tax burdens make clear why now is the time to act. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings examines Virginia’s tax structure in this presentation. While the state maintains a moderate 5.75 percent individual income tax rate and a 6.0 percent corporate rate, the real burden comes from local taxes. Virginia localities can impose a BPOL gross receipts tax, a business personal property tax with no de minimis exemption, and other levies that vary by jurisdiction, creating significant compliance costs and effective rates that exceed the headline numbers. Combined with nonconformity on expensing and other structural issues, these local taxes make Virginia less competitive than states with no income tax. Florida and Texas impose no state personal income tax and offer far simpler, lower-burden environments. This presentation shows how redomestication allows Virginia business owners to move a company to another state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in Virginia, the local tax layer may justify making the move. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings explains Vermont’s poor tax competitiveness in this presentation. The state ranks 42nd on the Tax Foundation’s 2026 State Tax Competitiveness Index with a top individual income tax rate of 8.75 percent, a corporate rate of 8.5 percent, the highest effective property tax burden in the nation as a percentage of personal income, and a 16 percent estate tax. Vermont is considering further income tax increases that would worsen its ranking, while neighboring New Hampshire ranks 3rd after eliminating its individual income tax. Florida and Texas impose no state personal income tax and offer far more competitive environments. This presentation shows how redomestication allows Vermont business owners to transfer their company’s legal domicile to Florida or Texas without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in Vermont, the structural burdens and policy direction make a compelling case for change. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings examines Utah’s strong tax competitiveness in this presentation. The state ranks 15th on the Tax Foundation’s 2026 State Tax Competitiveness Index with a flat 4.5 percent individual and corporate income tax rate, permanent full expensing, no throwback rule, no capital stock tax, and an overfunded pension system at 104 percent. Utah serves as a model for states that impose all major taxes while maintaining broad bases and low rates. However, 4.5 percent is still a tax. Florida and Texas impose no state personal income tax. This presentation shows how redomestication allows Utah business owners to transfer their company from one state to another without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in Utah, the state does many things right, but zero remains the better number. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings explains why Texas remains one of the strongest states for business ownership and how redomestication provides seamless flexibility in this presentation. Texas ranks seventh on the Tax Foundation’s 2026 State Tax Competitiveness Index with no individual income tax, no estate tax, no inheritance tax, and a franchise tax that applies only to larger entities. The state has built a pro-business legal infrastructure including a dedicated Business Court and strong governance protections that have attracted major companies such as Tesla and ExxonMobil. This presentation covers the advantages of redomesticating into Texas from a high-tax state as well as the process for Texas-domiciled businesses that need to move the entity when life circumstances require relocation. Redomestication transfers the company to a different state, without creating a new entity, and without triggering federal income tax when performed correctly. The company retains its FEIN, contracts, credit history, and bank accounts. Whether you are moving into Texas or out of Texas, the process is flat-fee, remote, and handled end-to-end by a licensed attorney and CPA admitted in Texas. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings explains the top six mistakes business owners make when selling or transferring an LLC in this presentation. From operating without a proper operating agreement, to dissolving the company instead of redomesticating it, failing to register in the state where you actually conduct business, using free contract templates, commingling personal and business funds, and neglecting to update formation documents, these common errors expose owners to unnecessary risk, tax consequences, compliance violations, and lost value. This presentation walks through each mistake with practical guidance on how to avoid them and protect both the seller and the buyer during a transfer. Learn why redomestication is often the correct path instead of dissolution and how proper planning preserves your FEIN, contracts, credit history, and liability protection. If you are preparing to sell or transfer your company, this presentation will help you avoid costly pitfalls. Learn more: https://www.cummings.law

Attorney and CPA Chad D. Cummings explains the five critical steps every LLC owner must take before selling a membership interest in this presentation. From reviewing the operating agreement for transfer restrictions, to choosing between a membership interest sale and an asset sale, cleaning up compliance issues before due diligence, evaluating the state of domicile and the benefits of redomestication, and obtaining a professional valuation, each decision affects the purchase price, tax consequences, and risk of post-closing disputes. This presentation walks through the practical, legal, and tax considerations that protect both sellers and buyers and help maximize value in an LLC transaction. Whether you are preparing to sell or considering acquiring an existing LLC, these steps reduce surprises and position the deal for success. Learn more: https://www.cummings.law

Attorney and CPA Chad D. Cummings highlights Tennessee’s dramatic tax reform success in this presentation. The state has climbed from 38th to 8th on the Tax Foundation’s 2026 State Tax Competitiveness Index by fully eliminating its individual income tax, making it one of the best states in the country for pass-through businesses. Tennessee also maintains a pension system funded at 108 percent and strong fiscal discipline. This presentation shows how redomestication allows business owners to transfer a company legal domicile without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. For owners in neighboring states still paying income taxes ranging from 4.25 percent to 6.5 percent, the comparison is clear. Learn about redomestication: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings presents this overview of why South Dakota ranks second on the Tax Foundation’s 2026 State Tax Competitiveness Index. The state imposes no individual income tax, no corporate income tax, and no gross receipts tax, along with no estate tax, no inheritance tax, and no tangible personal property or inventory taxes. With a fully funded pension system at 100 percent and a simple, transparent tax structure built on sales and property taxes, South Dakota offers one of the most competitive environments in the country. This presentation shows how redomestication allows business owners to transfer their company to a new state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. Whether you are coming from a high-tax state in the upper Midwest or looking for a stable zero-income-tax jurisdiction, this is the proper legal mechanism. Learn more: https://www.cummings.law/redomestication/