Was His Home Connecticut or Florida? The Difference Is a $13 Million Tax Bill
As states take a closer look at wealthy taxpayers with homes in multiple jurisdictions, determining where someone truly calls home can carry enormous tax consequences. In a Wall Street Journal article, Hodgson Russ Partner Tim Noonan discusses the growing number of residency audits, highlighting how states are increasingly challenging taxpayers' domicile claims. The article focuses on the estate of healthcare executive Jack Anderson, whose heirs are disputing a $13.2 million Connecticut estate and gift tax assessment. While Anderson maintained a custom-built oceanfront residence in Florida and established several legal ties there, Connecticut argued that his substantial property holdings, personal connections, and time spent in the state made him a Connecticut domiciliary at the time of his death. A recent Connecticut Supreme Court ruling ordered a new trial and lowered the burden of proof required for the estate to challenge the state's position, a decision that could have significant implications for future residency and estate tax disputes.