#LegalBytes: The Official Podcast of Cummings & Cummings Law

Attorney and CPA Chad D. Cummings explains that California has no exit tax. There is no toll for leaving. California taxes residents on all income wherever earned, taxes part-year residents for the period they were residents, and can still tax California-source income after you go. The real risk is the state deciding you never left. Residency is a facts-and-circumstances test: home, spouse, children, license, voter registration, banking, doctors, and days in the state. Changing an address while leaving the house, family, and routine behind looks like travel, not a move. The same problem attaches to the company. A California registration, filings, and home address are exhibits that the departure is unfinished. Proposition 40 would impose a one-time tax of up to five percent on net worth over a billion dollars. Most owners are not in that group. The lesson is the direction: a state that taxes you for standing inside its borders will keep looking for new reasons to reach further. Florida and Texas impose no personal income tax, so there is no residency fight of that kind. Redomestication moves the existing company and keeps the federal employer identification number, contracts, bank accounts, credit history, and in almost every case the name. That creates a dated official record that the business left. Learn more about transferring your corporation out of California: https://www.cummings.law/redomestication/move-business-out-of-california

Attorney and CPA Chad D. Cummings examines Bimbo Bakeries USA’s move of its American headquarters from Horsham, Pennsylvania to Irving in the Dallas–Fort Worth area. The company behind Entenmann’s, Sara Lee, Thomas’, Arnold, Little Bites, and Mrs. Baird’s has more than twenty thousand employees and more than fifty bakeries. After seventeen years outside Philadelphia, leadership is already working from the new Texas office. What moved is the corporate flag—about a hundred headquarters jobs. The bakeries, delivery routes, and the people who bake and stock the shelves stayed put. The company is keeping its Conshohocken sales center and Philadelphia-area operations. Dallas is central, closer to the parent office in Mexico City, and already home to bakeries, sales centers, and distribution facilities; the American business started in Texas with the 1998 purchase of Mrs. Baird’s. The lesson is that the state where a business is registered is not the same as the state where the work happens. Trucks, crews, customers, and buildings can stay in place while the company itself becomes a Texas or Florida company. Learn more about transferring your business out of Pennsylvania: https://www.cummings.law/redomestication/move-business-out-of-pennsylvania

In this presentation, Attorney and CPA Chad D. Cummings explores intellectual property law generally and its intersection with artificial intelligence specifically, including the ethical considerations thereof, for the benefit of his students at Florida Gulf Coast University.

I, Robot clip: https://www.youtube.com/watch?v=siHfHUm3HGE

2001: A Space Odyssey clip: https://www.youtube.com/watch?v=NqCCubrky00 

Attorney and CPA Chad D. Cummings notes that CG Oncology, a Nasdaq-traded bladder-cancer biotech valued near seven billion dollars, moved its headquarters from Irvine, California to Dallas’s Pegasus Park. The company cited talent, investors, partners, a more central location, modern facilities, cost advantages, and proximity to UT Southwestern and the University of Texas at Dallas. It describes itself as remote first. The Dallas office is a legal and administrative home, not a factory floor, and a legal home can move without disturbing the rest of the business. Tesla, Oracle, Hewlett Packard Enterprise, Charles Schwab, McKesson, Chevron, SpaceX, X, and Public Storage have already left California for Texas. Florida and Texas impose no state-level personal income tax. For a pass-through entity that difference lands on the owner’s personal return. Tax Foundation data shows the average business relocating to a no-income-tax state keeps more than twelve thousand five hundred dollars a year. You do not need a seven-billion-dollar listing to make the same move. Redomestication keeps the federal employer identification number, contracts, bank accounts, credit history, and in almost every case the name. Same company. New state. Learn about transferring your LLC out of California: https://www.cummings.law/redomestication/move-business-out-of-california

Attorney and CPA Chad D. Cummings notes that Washington was told what would happen and it happened anyway. Public records show Starbucks warned Governor Bob Ferguson in 2025 that taxing headquarters functions such as staffing, information technology, security, and advertising would raise costs and put the company at a disadvantage to firms based elsewhere. Ferguson signed the largest tax increase in state history. A requested meeting with the Starbucks chief executive never happened. The state then passed its first income tax. Months later Starbucks announced a one-hundred-million-dollar hub in Nashville and hiring of up to two thousand people in Tennessee, after two rounds of layoffs had already hit nearly thirteen hundred Washington workers and headquarters employment had fallen from about thirty-seven hundred and fifty to roughly twenty-eight hundred. T-Mobile made the same point in writing: companies headquartered in Washington pay the expanded sales tax on advertising services; companies headquartered elsewhere do not. Lawmakers left the tax in place. Learn more about moving your LLC or corporation out of Washington state: https://www.cummings.law/redomestication/move-business-out-of-washington

Attorney and CPA Chad D. Cummings notes the Telegraph’s August 26 report that New York City has admitted it got the pied-à-terre tax rollout wrong. A court filing showed roughly one in three notices about the luxury second-home levy went to the wrong people. The mayor acknowledged the errors, and a judge has paused the rollout. The tax applies to city residential property that is not the owner’s primary residence and sits above a value threshold. It was sold as a levy on spare luxury apartments. What arrived in the mail were notices that forced ordinary homeowners to prove they live in their own homes, on the city’s timetable, using the city’s forms. When a government aims a tax at a narrow group, it still has to identify that group, and incomplete data sweeps in people who were never the target. Those people pay in time, stress, and professional fees that never appear in the revenue projections. The city’s budget shortfall did not disappear because the notices were wrong. The tax will be corrected and reissued, and the search for the next category of taxpayer will continue. Learn more about transferring your LLC or corporation out of NY: https://www.cummings.law/redomestication/move-business-out-of-new-york

Attorney and CPA Chad D. Cummings reviews a late-June Telegraph report on what it called America’s wealth tax war. New York City adopted a pied-à-terre tax on high-value second homes, with multiple brackets and a top rate of six and a half percent on the most expensive properties. The mayor projects half a billion dollars in annual revenue. Governor Kathy Hochul had previously resisted income and corporate tax increases on the ground that wealthy residents would leave; she now backs the surcharge. The chief executive of Partnership for New York City told the Telegraph the tax was implemented for purely political reasons. Learn more about transferring your LLC out of New York: https://www.cummings.law/redomestication/move-business-out-of-new-york

Attorney and CPA Chad D. Cummings examines Starbucks’ latest filing in Washington State. Two hundred twenty-four corporate jobs are being cut at the SoDo headquarters in Seattle—the second round this year. Roughly one hundred twenty of those positions are information technology roles that moved to Nashville; the employees declined to relocate. The rest worked on store design. Starbucks announced the Nashville office last year and is expanding there while keeping the headquarters flag in Seattle. Local reporting indicates Washington could lose as much as seven hundred fifty million dollars in tax revenue in the coming years from growth that is happening in Tennessee instead. Starbucks was founded at Pike Place Market in 1971 and is as tied to Seattle as any company is to any city, yet new operations are going to a state with no personal income tax. Washington has no personal income tax either, but it does have a gross-receipts business and occupation tax, a capital gains tax, and a city payroll tax layered on top. Learn more about moving your company out of Washington state: https://www.cummings.law/redomestication/move-business-out-of-washington

Attorney and CPA Chad D. Cummings reviews the Tax Foundation map of what a hundred dollars actually buys across U.S. metro areas, drawn from Bureau of Economic Analysis regional price data. In the San Francisco metro area that hundred dollars buys about eighty-four dollars and fifty-eight cents of goods and services. Los Angeles is eighty-six dollars and sixty-one cents. San Jose is eighty-eight dollars and sixty cents. The New York metro area is eighty-eight dollars and ninety-one cents. Six of the ten most expensive metro areas in the country are in California. The same hundred dollars is worth ninety-nine dollars and seventy-eight cents in Houston, a hundred two dollars and forty-four cents in Austin, a hundred six dollars and sixty-nine cents in San Antonio, and more than a hundred fourteen dollars outside Texas metro areas. The purchasing-power gap and the tax gap stack. California has the highest top marginal income tax rate in the country; New York and New Jersey are close behind. Florida and Texas impose no personal income tax. Learn more about transferring your LLC to another state: https://www.cummings.law/redomestication/