Part II · Jurisdictions · No. 05

Florida

The principal high-net-worth migration destination in the United States. No state income tax, the constitutional homestead exemption with absolute creditor protection, capped vessel sales tax, no state estate tax — and a built-out professional services infrastructure that has scaled with the demand.

Why this jurisdiction matters

Florida combines the structural advantages of no state income tax with two distinctive constitutional features: the homestead exemption and homestead-tax-cap provisions. For high-net-worth taxpayers moving from New York, New Jersey, California, Illinois, and Connecticut, Florida is the dominant destination.

The relevant tax regime

• No state individual income tax. The prohibition on a personal income tax is constitutional (Florida Constitution Article VII, §5).
• No state estate or inheritance tax.
• State sales tax. 6% state rate, plus county discretionary surtaxes (combined rates up to about 8%). Notable cap: tax on the sale of a single boat (and certain aircraft) is capped at $18,000 under Florida Statutes §212.05(1)(a)2., in effect since 1 July 2010; the cap covers surtax too, so it is reached at a $300,000 price.
• Property tax. Constitutional homestead exemption of $25,000 against all levies plus a second $25,000 against non-school levies (on assessed value between $50,000 and $75,000). Since 2025 the second exemption is indexed to inflation (Amendment 5, 2024). The Save Our Homes cap limits annual assessment increases on homestead property to the lower of 3% or CPI; non-homestead property has a 10% cap on non-school levies.
• Corporate income tax. 5.5% on Florida corporate income.
• Documentary stamp tax. On deed transfers at $0.70 per $100 of consideration (Miami-Dade $0.60); on promissory notes at $0.35 per $100.

Registration or residency mechanics

Establishing Florida residency for income, estate, and asset-protection purposes requires:

• Declaration of domicile filed with circuit court of new county of residence (Florida Statutes §222.17).
• Filing for Florida homestead exemption (in many cases the single most powerful documentary act).
• Florida driver's license; vehicle registration.
• Voter registration.
• Sale or significant downsizing of out-of-state primary residence.
• Move "near and dear" items; spouse and minor children typically.

Reporting and disclosure

Standard state-level entity records (Sunbiz annual reports list officers, managers or authorised persons). Since FinCEN’s March 2025 interim final rule, Florida-formed entities are exempt from Corporate Transparency Act beneficial-ownership reporting. Florida does not impose state-level beneficial-ownership reporting.

The substance question

Florida residency is contested principally by New York, California, and Massachusetts on departure. New York’s five primary factors (home, active business involvement, time, “near and dear” items, family) frame most audits. Florida homestead filing is a powerful objective signal. Day-count documentation is the standard defense; cell-tower data, credit-card receipts, and air-travel records reconstruct days. See state residency.

Recent changes

The $10,000 federal SALT cap (from 2018) encouraged migration. The One Big Beautiful Bill Act (Pub. L. 119-21) raised the cap to $40,000 from 2025, phased down for incomes above $500,000 and reverting to $10,000 in 2030, which slightly reduces that pressure. Voters approved Amendment 5 in November 2024, indexing the second homestead exemption to inflation from 2025. The Legislature placed a further homestead property-tax amendment (HJR 1F, June 2026 special session) on the 3 November 2026 ballot. It needs 60% approval; check the result before relying on current exemption amounts. Status as of October 2026.

Common asset classes parked here

• Yachts — capped sales tax, extensive moorage, no annual property tax.
• Trophy real estate — Palm Beach, Miami, Naples; homestead protection.
• Thoroughbred horses — Ocala-area breeding and training.
• Private aircraft — multiple FBOs; sales-tax neutral acquisition (with structuring).
• Family offices serving migrated principals.

Reviewed October 2026