#LegalBytes: The Official Podcast of Cummings & Cummings Law

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/