#LegalBytes: The Official Podcast of Cummings & Cummings Law

Attorney and CPA Chad D. Cummings notes that California’s proposed billionaire tax is producing the exits its supporters were warned about. Politico reports that Sergey Brin began cutting ties with the state late last year, following Larry Page. Peter Thiel moved to Miami and cited the tax environment. Don Hankey moved to Nevada and said he no longer felt wanted. Leading California tax attorneys told Politico they have quietly moved at least another half-dozen billionaire clients. If voters approve Proposition 40, the state expects about $100 billion, roughly one-third of the annual budget. Taxpayers have billions of reasons to establish residency elsewhere. The Franchise Tax Board has about $100 billion of reasons to argue they never left. California does not decide residency by a driver’s license. Inventor Gilbert Hyatt sold his California home, rented in Nevada, opened a Nevada bank account, and re-registered his vehicles before a roughly $150 million patent windfall. The Franchise Tax Board still went through his trash, read his mail, and contacted his rabbi. The fight lasted about a quarter-century, reached the U.S. Supreme Court three times, and left Hyatt paying about $11 million. Courts look for the center of life: purchases, doctors, family, property, and where the business actually sits. Residency attorney Christopher Manes put it plainly: you can buy the Palace of Versailles, but you have to actually leave. Meanwhile, state like Florida and Texas impose no personal income tax and no wealth tax. Redomestication can move an existing company without dissolving it. Changing the mailing address does not end the analysis. Learn how to move a company out of California: https://www.cummings.law/redomestication/move-business-out-of-california/

Attorney and CPA Chad D. Cummings notes that New York City’s second-home tax has already failed a basic test: identifying who owes it. The Telegraph reports that a judge ordered Mayor Zohran Mamdani’s administration to start again after thousands of primary residences were wrongly flagged for the surcharge. The mayor’s office admitted notices went out in error. A known tax can be modeled. A misclassification cannot. The owner of a primary residence still has to hire counsel, assemble records, and prove the city’s file is wrong, and that cost does not disappear when the assessment is later withdrawn. New York is already arguing over whether wealthy residents and firms will keep absorbing new levies. A court order to restart the rollout is an execution problem, and execution problems belong in the jurisdiction’s risk profile. Redomestication can move an existing company without dissolving it. The expensive tax is not always the one with the highest rate. Sometimes it is the one you were never supposed to owe. Learn about how to move your company out of New York without starting over: https://www.cummings.law/redomestication/move-business-out-of-new-york/

Attorney and CPA Chad D. Cummings notes that Illinois will be the first state with a dedicated tax on digital asset transactions. Beginning January 1, 2027, the rate is 0.2 percent of the value of digital assets exchanged, transferred, or stored for Illinois customers. The tax reaches brokers with an Illinois place of business or at least $100,000 of Illinois gross receipts in a 12-month period. Registration is broader than collection. Jones Day reports that even one covered transaction with an Illinois customer requires a certificate from the Department of Revenue, and operating without one can be a Class 3 felony. Storage is taxable, so exchanges, custodial wallets, and cold-storage services can fall in. Receipts are presumed Illinois unless the broker proves otherwise, and implementing rules were not yet out. Possible Commerce Clause and Internet Tax Freedom Act challenges do not pause the compliance burden. A digital company can serve the country from almost anywhere. It cannot assume every state imposes the same cost. Florida and Texas impose no personal income tax. Redomestication can move an existing company without dissolving it. Illinois just created a regime no other state has, and firms now have to price it. Learn about how to move your company out of Illinois and keep your EIN: https://www.cummings.law/redomestication/move-business-out-of-illinois/

Attorney and CPA Chad D. Cummings notes that Guinness is ending brewing at its Baltimore-area facility after eight years, and the site was not a failed experiment. Diageo’s Maryland operation drew more than 2 million visitors. Management still concluded continued brewing was no longer sustainable, citing rising operating costs, shifting tastes, and broader economic pressure. The cut had already started. Three years earlier Diageo eliminated roughly 100 jobs at Halethorpe and ended most commercial brewing, leaving the taproom and experimental brewery. Now the production itself is going, and Chicago is Guinness’s only U.S. brewery. Companies rarely announce that a state is hostile. They run the numbers and send the next dollar of capital somewhere else. A popular facility can still lose the internal competition for investment. Florida and Texas impose no personal income tax. Redomestication can move an existing company without dissolving it. Location is an operating decision, and operating decisions get revisited when the numbers stop working. Learn about redomiciling your company out of Maryland: https://www.cummings.law/redomestication/move-business-out-of-maryland/

Attorney and CPA Chad D. Cummings notes that Ken Griffin is betting $3 billion that Miami needs a university, not only another headquarters. The gift is the largest an American university has received. About $1 billion supports Carnegie Mellon’s Pittsburgh campus, including a renamed Kenneth C. Griffin School of Computer Science. About $2 billion builds a 15-acre campus in Wynwood. Students are expected in 2029, roughly 1,200 undergraduates and graduates, concentrated on national security, health, climate resilience, and advanced manufacturing. Citadel moved from Chicago to Miami in 2022. Griffin is developing a roughly $2.5 billion headquarters and had already committed about $300 million across the metro area. Executives and capital arrive quickly. Engineers and founders take longer. Griffin wants graduates to stay, start companies, and pull the next class of talent. Florida and Texas impose no personal income tax. Redomestication can move an existing company without dissolving it. An office lease is a cycle. A campus is an attempt to keep the boom after the first wave of migrants is gone. Learn how to transfer a company to Florida: https://www.cummings.law/onboard/florida.html

Attorney and CPA Chad D. Cummings notes that JPMorgan Chase is betting on where wealth is moving inside Greater Houston, not only on downtown. The bank signed a lease at Hughes Landing in The Woodlands that lifts its office from about 67,000 square feet to about 157,000. The added space is for private wealth management and commercial banking. JPMorgan already had a temporary presence there, then a roughly 34,000-square-foot commercial banking lease in 2023. It is now more than doubling again, and it is still looking at the Energy Corridor, downtown, the Galleria, and southeast Houston. It opened a private banking office in Sugar Land in 2024. The bank already holds about $25.3 billion in local deposits as of June 30, 2025. It is not adding expensive bankers for symbolism. It is following businesses, entrepreneurs, and families into the suburbs. Texas financial growth is not only a Dallas story. Florida and Texas impose no personal income tax. Redomestication can move an existing company without dissolving it. Banks commit long-term space where they expect the next clients and the next assets to be. Learn how to transfer a company to Texas: https://www.cummings.law/onboard/texas.html

Attorney and CPA Chad D. Cummings notes that Florida is no longer waiting to be discovered. The Florida Chamber of Commerce is running a multimillion-dollar “Free Enterprise Florida” campaign on Chicago’s Interstate 55 that names Governor JB Pritzker runner-up for Florida Economic Developer of the Year. Chamber President Mark Wilson cites more than $2 billion of taxable income moving from Illinois to Florida and diverging population trends. The targets are specific: advanced manufacturing, aviation, and technology startups. Florida created a chief manufacturing officer to chase factory and headquarters dollars, not tourism slogans. Citadel’s move from Chicago to Miami is the visible precedent: payroll, executives, advisers, and the next hire follow the new center of gravity. The Chamber ran a similar effort in New York and says more states are coming. Companies do not pick locations in a vacuum. States now treat them as prospects. Florida and Texas impose no personal income tax. Redomestication can move an existing company without dissolving it. The billboards on the Stevenson Expressway are the loudest part of a recruitment strategy, not a joke. Learn how to transfer a corporation from Illinois to Florida: https://www.cummings.law/redomestication/redomesticate-corp-illinois-florida/

Attorney and CPA Chad D. Cummings notes that West Palm Beach is adding a talent pipeline, not just another tower. Vanderbilt has filed a complete master plan for a nine-acre graduate campus in the Government Hill district: nine buildings, more than 300,000 square feet of academic space, four buildings about ten stories, and about 1,000 graduate students in business and technology, targeted for 2029. The investment is more than $300 million. Companies and executives can move quickly. Specialized labor is the constraint that shows up next. A recurring class of graduates trained for finance, technology, and management changes whether the next expansion can be staffed locally instead of imported. Universities plan in decades, not lease cycles. Faculty, research, alumni, and employer relationships stay. Florida and Texas impose no personal income tax. Redomestication can move an existing company without dissolving it. When companies, capital, and a university occupy the same downtown, a migration story starts to look like a market. Learn how to transfer an LLC from Illinois to Florida: https://www.cummings.law/redomestication/redomesticate-llc-illinois-florida/

Attorney and CPA Chad D. Cummings notes that Morgan Stanley has chosen Dallas over Alpharetta, Georgia, for a new regional headquarters. Alpharetta already employs more than 3,000 Morgan Stanley people. Dallas still won about $684 million of direct investment and more than 3,800 new jobs. Texas is backing it with a $43.85 million Texas Enterprise Fund grant, the program’s largest financial-services award. The firm will occupy about 255,000 square feet at Fountain Place for a little more than four years, then move around 2031 into a new Uptown tower at 2401 McKinney Avenue under a 16-year lease. With Trammell Crow, total development is about $1.3 billion. Dallas previously approved incentives of up to $18.5 million. Banks pull lawyers, wealth managers, and risk professionals, which then pull the next bank. This is internal capital allocation, not flight from a city with no presence. Florida and Texas impose no personal income tax. Redomestication can move an existing company without dissolving it. A 16-year lease is how a financial center stops being a slogan. Learn how to transfer a corporation to Texas from New York: https://www.cummings.law/redomestication/redomesticate-corp-new-york-texas/

Attorney and CPA Chad D. Cummings notes that the Texas Stock Exchange has moved from a pitch to a working primary venue. On September 16, Texas Capital transferred two ETFs from the New York Stock Exchange to TXSE. The next day Westwood Holdings launched the first new ETF on the exchange. Two more funds followed. Primary corporate listings are scheduled to begin October 5. Energy Transfer, Sunoco, USA Compression Partners, Dillard’s, and Texas Capital Bancshares are among the companies expected to trade primarily there. NYSE Texas and Nasdaq Texas already operate from Dallas, so TXSE is competing with New York institutions that have planted Texas flags of their own. Early funds have local ties, but the Calamos Timpani Active SMID Growth ETF listed September 21 without a Texas investment thesis. A handful of listings is not a new Wall Street. It is the machinery of public capital moving closer to Texas companies. Florida and Texas impose no personal income tax. Redomestication can change a company’s legal home without dissolving it. The test is whether issuers choose Dallas because the market works, not because the company is from Texas. Learn about how to transfer an LLC from New York to Texas: https://www.cummings.law/redomestication/redomesticate-llc-new-york-texas/