Changing Places, Changing Taxes: Exploiting Tax Discontinuities

29 Pages Posted: 28 Apr 2020

See all articles by Julie Roin

Julie Roin

University of Chicago Law School

Date Written: February 17, 2020


President Trump’s decision to move his official state of residence from high-tax New York to no (income)-tax Florida has brought public attention to an issue that has long troubled scholars, designers and administrators of income tax systems: how the interaction of tax rules deferring the taxation of income and tax rules based on residency allows taxpayers to reduce and even avoid taxation of their deferred income. These discontinuities in tax treatment may lead to excessive migration, as well as reductions in state income tax revenues. This article explains what states would have to do to eliminate these avoidance opportunities. However, it also points out that many of these policy changes would create other tax discontinuities. Ultimately, it leaves open the question of whether making any of these changes would lead to fewer financial and behavioral distortions.

Suggested Citation

Roin, Julie, Changing Places, Changing Taxes: Exploiting Tax Discontinuities (February 17, 2020). U of Chicago, Public Law Working Paper No. 740, University of Chicago Coase-Sandor Institute for Law & Economics Research Paper No. 902, Available at SSRN: or

Julie Roin (Contact Author)

University of Chicago Law School ( email )

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773-702-5314 (Phone)

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