Where your client dies domiciled can create or eliminate an eight-figure estate tax bill. The Anderson case (Wall Street Journal Weekend Edition, August 8-9, 2026) turned on one fact: he claimed Florida but spent 5.5 months per year in Connecticut and only 3.5 in Florida.
A practitioner reference for the CPA, estate attorney, family-office CFO, and wealth advisor working with high-net-worth clients evaluating a change of state domicile. All 50 states and DC covered in one table: which have an estate tax, which have an inheritance tax, exemption thresholds, top marginal rates, and whether the structure is cliff or graduated. Companion checklist walks the residency-establishment mechanics — driver's license, voter registration, homestead, banking, and the roughly two dozen other actions that together determine whether a state tax authority accepts the domicile change. Every quantitative reference is verifiable to state statute; practitioners should confirm current law for specific engagements.
Ashlea Ebeling reported for the Wall Street Journal in the Weekend Edition of August 8-9, 2026 (“Was His Home Connecticut or Florida? The Difference Is a $13 Million Tax Bill”) on a Connecticut/Florida domicile dispute where the difference between the two states of tax residency at date of death produced an approximately $13 million estate tax swing. That case is not unusual. It is the modal high-net-worth family's exposure when the state of domicile is contested — the numbers scale directly with the size of the estate, and the state tax authority's incentive to challenge grows with the amount at stake.
This page pulls the state-by-state estate and inheritance tax picture together so the advisor can see the entire landscape in one reference, then walks the residency-establishment checklist that determines whether the domicile change is defensible if the origin state challenges. For deeper practitioner work on estate architecture generally — dynasty trusts, GRATs, IDGTs, SLATs, ILITs, charitable remainder trusts, IRC §6166 elections, §303 partial redemptions, §2032A special-use valuation — see the Institute's Estate Planning Decoded reference and the Family Office Reference Guide.
The case anchoring the WSJ article is the estate of Jack Anderson, a hospital-management-company CEO and early leader in the U.S. HMO industry, who died in 2015 at age 90. His estate was valued at approximately $108 million. Connecticut assessed $13.2 million in estate and gift tax, on the theory that Anderson remained a Connecticut domiciliary at death. The executor, Les Daniels, disputed the assessment, arguing that Anderson's true domicile was his 9,700-square-foot oceanfront home in Vero Beach, Florida.
Anderson had done nearly every one of the "official" things a practitioner would tell a client to do to establish Florida domicile. He held a Florida driver's license, Florida voter registration, and Florida gun registration. His will listed the Vero Beach home as his address. His autobiography, In My Time, consistently referred to Texas and then Florida as his home. He had invested heavily and personally in the Florida house — custom-built to his specifications, with a custom astronomy observatory (his hobby), a private boardwalk to the Atlantic, and hand-painted murals in the dining room. The family celebrated Christmas there.
Yet Anderson also maintained substantial Connecticut ties. He owned three condominiums in a 7-unit Victorian complex in Greenwich (originally a single 4,000-square-foot unit purchased in 1984, expanded to 9,000 total square feet by 2014 with two additional units — one for guests, one for household staff). He belonged to the Greenwich Country Club and the Clove Valley Rod & Gun Club in Dutchess County, New York. He had four cars registered in Connecticut (Jaguar, Bentley, two Lexuses) versus three in Florida (Jaguar, Bentley, Mercedes). Most consequentially, he registered for Connecticut tax withholding for his nurses.
The 2024 trial in the Connecticut Superior Court tax division lasted four days, involved ten witnesses, 200 exhibits, and estate tax returns totaling approximately 4,000 pages. The trial court judge found that Anderson's personal, social, and property connections were "generally equal" between Connecticut and Florida — but concluded the estate had failed to prove by clear and convincing evidence that Connecticut wasn't his true home.
The judge's dispositive finding was on time-in-state. Anderson typically spent:
| State | Months per Year | Season |
|---|---|---|
| Connecticut (Greenwich) | 5.5 months | May through mid-October |
| Florida (Vero Beach) | 3.5 months | November through mid-February |
| Arizona (mountaintop home) | 3.0 months | Mid-February through early May |
The judge's key statement, quoted in Ebeling's reporting: “Ultimately, the most persuasive evidence demonstrating Anderson's domicile is where he chose to spend his most valuable and limited resource: his time.” The judge specifically dismissed the importance of the "one-time administrative" acts — Florida driver's license, voter registration, opening Florida bank accounts, filing a declaration of domicile — as insufficient to overcome the time-in-state evidence.
Anderson spent MORE time in Connecticut than in Florida. He was claiming Florida as his domicile while spending 5.5 months per year in the state he was trying to escape and only 3.5 months in the state he was claiming as home. That is not a defensible domicile claim, no matter how many paperwork boxes are checked.
The practitioner rule this case establishes with brutal clarity: if a client is claiming a new state as domicile, that new state must be where the client spends the plurality of the year — and by a meaningful margin. Not 3.5 months out of 12. Not less than the origin state. The client's calendar itself is the primary evidence, and the calendar has to tell the story the paperwork tells. Anderson's calendar told the opposite story, and no license, voter registration, or declaration of domicile could overcome it.
For advisors: the first question in every domicile-change engagement is not “have we filed the paperwork?” It is “how many days per year will the client physically be in each state?” If the answer doesn't put the new state clearly in first place, the domicile change isn't happening — regardless of what the paperwork says.
The case reached the Connecticut Supreme Court, which in June 2026 lowered the burden of proof required for the estate to succeed. Under the original trial court standard, the estate had to prove Connecticut wasn't Anderson's true home by clear and convincing evidence — a demanding standard. The Supreme Court held that the correct standard is preponderance of the evidence — more likely than not. The Court remanded the case to the trial court for a new trial under the lower standard.
As of the WSJ report, the Anderson estate is preparing to retry the case. The $13.2 million tax liability remains contingent on whether the estate can now prove — under the new standard — that Connecticut was not Anderson's true home. Practitioners in Connecticut and other states applying analogous burden-of-proof standards should watch the trial-court outcome; a taxpayer win under the new standard could reshape domicile-audit practice in Connecticut and potentially influence courts in New York, Massachusetts, and other high-tax states.
1. Paperwork alone doesn't win. Anderson did the driver's-license/voter-registration/domicile-declaration checklist correctly. It wasn't enough. If the client is spending more time in the origin state, no amount of paperwork saves the domicile claim.
2. The 183-day rule is the practical floor, not the ceiling. Anderson spent only 3.5 months in Florida — nowhere near half the year. Even without a hard 183-day statutory test in Connecticut, the court used time-in-state as the dispositive factor. Advisors should target more than 183 days in the new state and fewer than 183 days (ideally under 120) in the origin state.
3. Employment relationships in the origin state are red flags. Anderson registered for Connecticut tax withholding for his nurses. That single administrative act — an ordinary payroll decision — became an evidentiary factor supporting Connecticut domicile because it suggested Anderson was employing Connecticut-based staff at his Connecticut residence.
4. Maintaining multiple origin-state properties is problematic. Anderson's expansion from one Greenwich condo (1984) to three Greenwich units totaling 9,000 square feet (by 2014) worked against the Florida-domicile claim. Retaining and expanding origin-state real estate signals continuing ties.
5. Contemporaneous documentation matters, but so does what you did over decades. Anderson's autobiography and his will both referenced Florida as his home. These are strong contemporaneous statements. They did not overcome the time-in-state pattern. Practitioners should treat autobiographical/testamentary statements as necessary but not sufficient.
6. The Supreme Court's burden-of-proof reduction is meaningful. Under the new preponderance standard, the estate no longer has to prove Connecticut wasn't Anderson's home by clear and convincing evidence — just that it's more likely than not. That's a materially lower bar. Similar future cases in Connecticut become materially winnable for taxpayers with facts less extreme than Anderson's.
Source: Ashlea Ebeling, “Was His Home Connecticut or Florida? The Difference Is a $13 Million Tax Bill,” Wall Street Journal Weekend Edition, August 8-9, 2026 (print headline: “Was His Home Greenwich or Florida?”). Additional expert commentary in the article: Timothy Noonan, Hodgson Russ (New York City); Julie Lavoie and Jeffrey Sklarz, counsel for the Anderson estate; Barbara Taylor, Reid and Riege (Hartford, Conn.).
The 2026 federal estate tax exemption is $15 million per individual (approximately $30 million for a married couple with proper portability elections) following the One Big Beautiful Bill Act. State-level exemptions and rates operate independently of the federal number, and in many cases the state exemption is materially lower than the federal — creating estate tax exposure at the state level for families whose federal exposure is zero.
| State | Exemption | Top Rate | Structure | Notes |
|---|---|---|---|---|
| Connecticut | $15.00M | 12% flat | Federal-linked exemption (moves with federal); flat rate above threshold | Post-OBBBA Connecticut exemption tracks the $15M federal number. Anchor state in the WSJ August 2026 CT/FL domicile dispute. |
| District of Columbia | $4.87M | 16% | Graduated (0.8%–16%) | State-set exemption, indexed annually — not federal-linked |
| Hawaii | $5.49M | 20% | Graduated (10%–20%) | One of the two highest top rates in the country |
| Illinois | $4.00M | 16% | Graduated (0.8%–16%) | Cliff considerations for estates near the threshold |
| Maine | $6.80M | 12% | Graduated (8%–12%) | Independent state cap with annual inflation adjustment — does not automatically track federal OBBBA changes |
| Maryland | $5.00M | 16% | Graduated (0.8%–16%) | Only state with both estate and inheritance tax |
| Massachusetts | $2.00M | 16% | Graduated (0.8%–16%) — cliff above threshold | Cliff effect: estates just over $2M face tax on entire estate, not just excess |
| Minnesota | $3.00M | 16% | Graduated (13%–16%) | Includes three-year lookback on gifts |
| New York | $6.94M | 16% | Graduated (3.06%–16%) — cliff at ~105% of exemption | Notorious cliff: estates over 105% of exemption lose exemption entirely |
| Oregon | $1.00M | 16% | Graduated (10%–16%) | Lowest exemption in the country — many families exposed |
| Rhode Island | $1.78M | 16% | Graduated (0.8%–16%) | Indexed to inflation; verify current-year threshold |
| Vermont | $5.00M | 16% flat | Flat rate above threshold | Straightforward flat structure |
| Washington | $2.19M | 35% | Graduated (10%–35%) | Top rate increased in 2025 legislation — highest in the country |
Exemption amounts and rates are as of 2026 based on then-current state statutes. Several states index exemptions annually. Connecticut's exemption is expressly tied to the federal exemption — post-OBBBA the CT threshold is $15M, moving with any subsequent federal change. Maine and DC have independent state-set exemptions with annual inflation adjustments and do not automatically track federal changes. The advisor should verify the current-year threshold and rate schedule for any specific engagement.
Inheritance tax is levied on the recipient, not the estate. Rates typically vary by the beneficiary's relationship to the decedent — spouses and lineal descendants often exempt, siblings/nephews/nieces at intermediate rates, unrelated beneficiaries at the highest rates.
| State | Rate Range | Structure | Notes |
|---|---|---|---|
| Kentucky | 0%–16% | By beneficiary class (Class A/B/C) | Class A (spouses, children, parents) exempt; Class C (unrelated) at highest rates |
| Maryland | 0%–10% | By beneficiary class | Non-lineal at 10%; also has state estate tax |
| Nebraska | 1%–15% | By beneficiary class | Immediate family at low rates; unrelated at 15% |
| New Jersey | 11%–16% | Non-lineal beneficiaries only | Spouses, children, parents exempt; siblings and non-relatives taxed |
| Pennsylvania | 0%–15% | By beneficiary class | Spouses 0%; lineal descendants 4.5%; siblings 12%; other 15% |
Iowa's inheritance tax was fully repealed effective 2025. Practitioners with older reference material should confirm current status of the tax in each jurisdiction — several states have modified or repealed inheritance taxes in recent years.
These 32 states impose neither an estate tax nor an inheritance tax at the state level. High-net-worth families in high-tax-exposure states frequently evaluate a change of domicile to one of these jurisdictions, particularly the six no-income-tax states (Florida, Texas, Nevada, Tennessee, Wyoming, South Dakota — plus Washington and New Hampshire on limited income) that combine estate-tax neutrality with income-tax neutrality.
| State | State Income Tax | Practitioner Note |
|---|---|---|
| Florida | None | Most common destination for CT, NY, MA, NJ, IL migrations. Homestead exemption is a well-defined domicile marker. |
| Texas | None | Second most common destination. No estate, no income; homestead protections strong. |
| Nevada | None | No income tax; asset protection trust jurisdiction adds value beyond estate. |
| Wyoming | None | Dynasty trust and asset protection jurisdiction; small population makes residency more scrutinized. |
| Tennessee | None (Hall Tax repealed 2021) | No estate, no income; asset protection trust available. |
| South Dakota | None | Dynasty trust jurisdiction of choice for many advisors; asset protection trust rules highly favorable. |
| Alaska | None | No estate, no income; APT jurisdiction; geographic friction limits practical use. |
| New Hampshire | Limited (interest/dividends only, phased out 2027) | No estate, no wage income tax. |
| Other no-estate-tax states | Various | Arizona, Arkansas, California, Colorado, Delaware, Georgia, Idaho, Indiana, Kansas, Louisiana, Michigan, Mississippi, Missouri, Montana, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, South Carolina, Utah, Virginia, West Virginia, Wisconsin — all have state income tax but no estate/inheritance tax |
1. Oregon — $1M exemption is the lowest in the country. Any family with meaningful real estate, retirement accounts, and business interests is exposed.
2. Massachusetts — $2M exemption with cliff structure. Estates just over $2M face tax on the entire estate, not just the excess. Cliff creates strong incentive to structure below the threshold or move domicile.
3. Washington — $2.19M exemption plus the highest top rate in the country (35% after 2025 legislation). The combination is uniquely aggressive.
4. Minnesota — $3M exemption plus three-year gift lookback rule that can pull recent gifts back into the taxable estate.
5. New York — $6.94M exemption but with the notorious "cliff" that eliminates the exemption entirely for estates over ~105% of the threshold. An estate at 106% of exemption faces tax on the entire estate value from dollar one.
Changing state of residency for tax purposes is not a single action. Origin states, particularly aggressive collectors like New York, California, Connecticut, Massachusetts, and Illinois, apply multi-factor tests to determine whether a claimed change of domicile is real or a paper exercise. A defensible domicile change generally requires a preponderance of actions across roughly two dozen categories, ideally accomplished in the calendar year of the claimed change with contemporaneous documentation. The checklist below reflects the modal advisor's protocol for a client changing residency from a high-tax to a no-estate-tax state.
This checklist is intentionally comprehensive. The advisor's judgment on which items are essential vs. supplementary depends on the origin state's audit posture, the size of the estate, and the specific facts of the client's ongoing ties. For an aggressive origin state (New York, California) with a large estate, treat the entire checklist as required. For a less aggressive origin state and a smaller estate, some items may be practical to defer. When in doubt, complete the full checklist.
New York's Department of Taxation and Finance runs one of the most sophisticated domicile-audit operations in the country. A typical audit examines five factors: (1) location of home, (2) location of active business involvement, (3) time spent in each location, (4) location of items "near and dear" (family heirlooms, pets, safety deposit contents), and (5) family connections. No single factor is dispositive. The audit produces a determination on the preponderance of evidence.
California's Franchise Tax Board applies a similar multi-factor test with particular attention to physical presence and business ties. Connecticut, Massachusetts, and Illinois follow analogous approaches with variations in emphasis.
The specific numbers in the case that anchored this reference (per Ashlea Ebeling's Wall Street Journal reporting, Weekend Edition August 8-9, 2026): the estate at issue was in the range that produced an ~$13 million tax differential between the two claimed domiciles. That is not a theoretical exposure. It is what the state authority actually assessed, subject to the litigation outcome. Every advisor working with an HNW client considering a domicile change should treat that number as the order of magnitude at stake.
“Each advisor is strong. All advisors properly led are unstoppable.”
This reference is published for practitioner education under the publisher exception recognized by Lowe v. SEC (472 U.S. 181, 1985). It is not investment advice, tax advice for any specific client, legal advice, or personalized financial guidance. State estate tax and inheritance tax rules change frequently; the advisor is responsible for verifying current law in the specific jurisdictions relevant to a specific engagement. The residency-establishment checklist reflects general professional practice and does not constitute legal advice for any specific domicile change. Every quantitative reference on this page is verifiable against then-current state statutes as of the 2026 publication date; the advisor applying this material to a client engagement should confirm current-year applicability.