#LegalBytes: The Official Podcast of Cummings & Cummings Law

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/

Attorney and CPA Chad D. Cummings examines Deadline’s report that Paramount’s chief executive has told top executives he will begin moving the company out of California on October first if the state attorney general will not negotiate a settlement in the Warner Bros. Discovery case. Tennessee, Texas, and Georgia are under consideration. The Department of Justice, the European Union, and the United Kingdom cleared the merger. Twelve state attorneys general and the Writers Guild sued to stop it. Trial is set for March 2027, and contractual ticking fees are projected to exceed one billion dollars by then. Even opponents of the merger are asking the attorney general to settle, arguing that prolonged uncertainty costs more jobs than the deal itself. The attorney general called the relocation threat blackmail. Site Selection’s 2026 survey of site consultants ranked Nashville, Atlanta, Charlotte, and Dallas as the top cities for headquarters; California received the most votes for worst business climate in America for the second year running. Area Development ranked Georgia first, Texas third, and Tennessee sixth. Learn more about moving your LLC out of California to a new state: https://www.cummings.law/redomestication/move-business-out-of-california

Attorney and CPA Chad D. Cummings examines the rise of Y’all Street. Dallas has become the second-largest financial center in the United States by employment, with more than three hundred eighty-six thousand people working in financial activities in the Dallas–Fort Worth–Arlington area. Goldman Sachs is building a five-hundred-million-dollar campus expected to hold more than five thousand employees—the firm’s largest U.S. workforce outside New York. Scotiabank, Fifth Third, Vanguard, Nasdaq, and the New York Stock Exchange have all expanded in the region. The Texas Stock Exchange began its phased rollout in July, with full trading and listings expected in 2027. Texas has no corporate or personal income tax, a large workforce, and strong inbound migration from California and New York. Finance has the least physical reason to move, yet the industry is relocating permanent campuses. The same tax arithmetic that drives large institutions applies to smaller companies, and for a pass-through entity it reaches the owner’s personal return directly. The institutions with the most invested in staying put are leaving anyway. The question is what is actually keeping your company where it is. Learn more about transferring your company to Texas: https://www.cummings.law/onboard/texas.html

Attorney and CPA Chad D. Cummings examines the Maryland Tax Court’s August 14 decisions striking down the state’s Digital Advertising Gross Revenues Tax. In three cases involving Apple, Google, and Peacock TV, the court reversed the comptroller’s denial of refund claims and ordered the state to return the money with interest. Maryland enacted the tax in 2021 as the first of its kind, imposing rates from two and a half to ten percent on gross digital advertising revenue based on a company’s worldwide revenue rather than its activity in the state. Only companies above one hundred million dollars in global revenue were covered. Through July the state had collected about five hundred thirty-five million dollars, which remains unspent. The court held that the tax violates the federal Internet Tax Freedom Act because Maryland taxes digital advertising while taxing nothing comparable in traditional media. A federal appeals court had already struck down part of the same law on First Amendment grounds, and Governor Larry Hogan had vetoed the original bill. The broader lesson is about legislative posture: Maryland identified a growing category of commerce, wrote a statute aimed only at it, overrode a veto, collected half a billion dollars, and defended the tax for five years. California has proposed similar measures; Washington enacted one now under challenge. Florida and Texas impose no personal income tax and have not pursued levies of this kind. Large companies can litigate for years. Most businesses cannot. What they can do is choose a state whose legislature is not looking for them. Learn more about transferring your company out of Maryland: https://www.cummings.law/redomestication/move-business-out-of-maryland

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’s assets are a laptop, a methodology, and a client list; almost nothing about the work depends on the state named on the certificate of formation. Yet many consultants still pay California’s $800 minimum franchise tax, New York’s publication and filing costs, or pass-through taxes in Illinois and New Jersey years after leaving. Because most practices are single-member LLCs or S corporations, profits land directly on the owner’s personal return. Florida and Texas impose no personal income tax. Tax Foundation data shows the average business relocating to a no-income-tax state retains more than $12,500 each year. Both states also offer strong asset-protection statutes and predictable business law—valuable when the product is judgment that can later be second-guessed. Redomestication moves the existing entity so the federal employer identification number, engagement letters, banking, and professional liability coverage continue without interruption. Owners need not live in the destination state; a commercial registered agent satisfies the street-address requirement. Nexus and personal residency remain separate questions for counsel and a tax professional and should be resolved before any filing. Learn more about transferring your consulting company to a new state: https://www.cummings.law/redomestication/

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/