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. Florida's prohibition on state income tax is constitutional (Florida Constitution Article VII, §5).
• No state estate or inheritance tax.
• State sales tax. 6% state rate; combined rates approach 7.5% with local additions. Notable cap: vessel sales-tax capped at $18,000 per single sale (Florida Statutes §212.05(1)(a)2.a.).
• Property tax. Constitutional homestead exemption of up to $50,000 of assessed value; Save Our Homes 3% annual cap on assessment increases for homestead property.
• 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. CTA BOI reporting applies to Florida entities. Florida does not impose state-level information reporting separate from federal.

The substance question

Florida residency is contested principally by New York, California, and Massachusetts on departure. The five primary factor test (home, business, time, near-and-dear, family) applies. 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 2017 federal SALT cap accelerated Florida migration meaningfully. Florida raised the homestead exemption second tier (above first $25,000) periodically. The state has not enacted notable adverse changes; the trajectory is consistently favorable for inbound high-net-worth residents.

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 May 2026