Massachusetts to New Hampshire: The Cleanest Tax Arbitrage Corridor in the Country

No corridor in the country has a simpler headline. Massachusetts taxes most income at a flat 5 percent and adds a 4 percent surtax on taxable income above 1,107,750 dollars for 2026, for a top rate of 9 percent. New Hampshire, one state line away, taxes none of it. It never taxed wages, and as of January 1, 2025 it no longer taxes interest and dividends either, after House Bill 2 repealed the Interest and Dividends Tax that had stepped down from 5 percent to 4 percent for taxable periods ending on or after December 31, 2023 and to 3 percent for periods ending on or after December 31, 2024. New Hampshire is now a genuine zero-income-tax state rather than the partial one it was for a century.

People act on that gap in visible numbers. The IRS tracked 10,603 tax returns for 2023 that had moved from Massachusetts to New Hampshire against 6,594 moving the other way, a net gain of 4,009 filers, and the AGI flow was lopsided in a way the headcount understates: 1.4 billion dollars arriving in New Hampshire against 557,595,000 dollars leaving, for a net gain of 870,606,000 dollars in a single year. Across 2012 through 2023 the net figure is 5.95 billion dollars of adjusted gross income, from IRS data analyzed for the Josiah Bartlett Center for Public Policy by the Pioneer Institute. Census migration estimates tell the same story with more people in it: 369,368 Massachusetts residents moved to New Hampshire between 2005 and 2024, 223,720 went the other direction, and the net was 145,648.

What makes this corridor different from the Florida ones is not the size of the delta. It is the adjacency. The border between these two states is a commute, not a flight. Most of the people who make this move do not stop having a Massachusetts life, because their employer, their office, their doctor and their parents are all still forty minutes south. That single fact reorganizes the entire risk picture. In a Massachusetts-to-Florida move, the question that decides everything is domicile. In a Massachusetts-to-New Hampshire move, domicile is often the part you get right, and the exposure that survives is about sourcing and about days.

Our Massachusetts residency guide rates the state 4 out of 5 on exit stickiness and 4 out of 5 on audit aggressiveness, and the Department of Revenue places the burden of proving a domicile change on the taxpayer while requesting an unusually large volume of records once a nonresident return follows years of resident filing. Our New Hampshire residency guide rates New Hampshire 1 and 1, because New Hampshire audits nobody for leaving and has no individual income tax return for anyone to file in either direction. This article is informational and is not legal or tax advice; work through your own facts with a qualified CPA or tax attorney.

M.G.L. c. 62, section 1(f) defines a resident or inhabitant of Massachusetts two ways. The first is domicile: any natural person domiciled in the commonwealth. The second is the statutory prong, and it is the one people moving from Massachusetts to New Hampshire underestimate. A person who is not domiciled in Massachusetts is still a resident if they maintain a permanent place of abode in the commonwealth and spend, in the aggregate, more than 183 days of the taxable year in the commonwealth, including days spent partially in and partially out of the commonwealth. A day spent in Massachusetts while on active duty in the armed forces does not count.

Read the abode prong slowly, because it does not require you to live in Massachusetts. It requires you to maintain a dwelling and to be physically present on more than 183 days. DOR guidance in TIR 95-7 defines a permanent place of abode as a dwelling place continually maintained by a person, whether or not owned by that person, and it includes a dwelling owned or leased by a spouse. The exclusions are narrow and specific: a college dormitory room, a hospital room, military barracks, a seasonal camp, or a temporary stay set up for a specific limited purpose lasting less than a year. A condominium you kept in Boston because your daughter is finishing high school there is none of those things.

Now put that prong next to the corridor. From Nashua or Salem or Portsmouth, 184 days in Massachusetts is not an exotic scenario for someone with a Boston office, a Massachusetts family, and a Massachusetts property they did not sell. It is roughly three and a half days a week, counting any day you set foot in the state for any reason. The two facts have to combine to matter, which is why the standard advice on this corridor is to break one of them decisively, but people frequently break neither and assume a New Hampshire address settles it.

The domicile prong runs on a different logic entirely. DOR describes domicile as a person’s true home, the place of their most important family, social, economic, political and religious ties, and it requires abandoning the old domicile, establishing residence at the new place, and intending to make it a permanent or indefinite home with no present intent to return. The burden of proving the change falls on the taxpayer asserting it. The published factor list is unusually detailed, covering home purchase or lease, moved personal property, permanent employment, closed and opened bank accounts, sold Massachusetts real estate or canceled leases, address change notices, voter registration, driver license and vehicle registration, and club or church memberships, and DOR backs it with requests for five years of address history, day-by-day presence records, and the IRS office where federal returns were filed.

The case to read on this corridor is Welch v. Commissioner of Revenue, No. 24-P-109, decided by the Massachusetts Appeals Court on April 3, 2025, affirming an Appellate Tax Board decision from November 29, 2023. It is the closest thing this corridor has to a canonical example, and its lesson is the opposite of the one people expect.

Craig Welch co-founded AcadiaSoft, Inc. in Massachusetts in 2005 and took founder’s stock. He served as founder, president, treasurer, clerk and director, and later as CEO. All AcadiaSoft personnel reported to him. He was involved in hiring, assessing legal claims, formulating business plans and seeking equity financing, and he worked roughly eighty hours a week in the company’s early years. His reported wage income over that period was close to nothing: no wages at all for 2003 through 2005, 5,533.77 dollars in 2006, and 7,235.42 dollars in 2007. By 2015 he held 11.86 percent of AcadiaSoft’s common stock.

The Welches moved to New Hampshire on or about April 30, 2015, which the court described as the last day of their Massachusetts residency. On June 29, 2015, as a New Hampshire resident, Welch sold his shares back to the company in a repurchase, receiving cash proceeds of 4,744,759.96 dollars against a reported basis of zero. He reported the sale but excluded the gain from Massachusetts income. The Commissioner assessed 335,968.62 dollars in tax, interest and penalties.

Here is the part that matters. The Commissioner never disputed that Welch had genuinely become a New Hampshire resident. The opinion says so directly: the commissioner does not argue that when Welch sold his AcadiaSoft shares on June 29, 2015, his domicile was Massachusetts, and so the court did not consider that issue. He moved, the move was real, the move was accepted, and he still lost.

He lost on sourcing. G.L. c. 62, section 5A taxes nonresidents on income derived from or effectively connected with any trade or business, including employment, carried on in Massachusetts, and a 2003 amendment expanded that to reach gain from the sale of a business or of an interest in a business. The implementing regulation, 830 CMR 62.5A.1(3)(c)(8), starts out sounding like a safe harbor: the rule generally does not apply to the sale of shares of stock in a C or S corporation to the extent the gain is characterized as capital gain for federal purposes. Then it adds the exception that decided the case. Such gain may give rise to Massachusetts source income if, for example, the stock is related to the taxpayer’s compensation for services.

The Board found, and the Appeals Court agreed, that the founder’s stock was compensatory in nature. The evidence was the wage history. Welch had worked eighty-hour weeks for a decade at pay that was not commensurate with the effort, and the equity was what he had actually been paid with. The gain was therefore derived from and effectively connected with his trade or business or employment in Massachusetts, and it was taxable as Massachusetts source income even though he was a New Hampshire resident when the wire cleared. AcadiaSoft had apportioned all of its income to Massachusetts on its own corporate excise returns while headquartered there, which did not help.

Set the two dates next to each other: April 30 and June 29, 2015. Two months. Every planning instinct says move first and sell second, and he did, and it made no difference, because the thing Massachusetts taxed was not where he lived in June. It was where he had worked from 2005 to 2015. On this corridor, moving your domicile changes the state that taxes your next dollar. It does not change the state that earned your last decade.

Almost every state with a residency test has one day count. Massachusetts, for a New Hampshire resident who still works in Massachusetts, effectively has two, they measure different things, and both of them start from a presumption you have to rebut with records.

The first is the statutory residency count in section 1(f). It counts calendar days of presence in Massachusetts for any reason at all, and any part of a day counts as a whole day. A Saturday lunch in Cambridge counts. Driving your mother to an appointment in Worcester counts. It is not a count of work days and it does not care why you were there. Paired with a retained Massachusetts dwelling, more than 183 of those days makes you a Massachusetts resident on your worldwide income, regardless of where your domicile is.

The second is the working-days apportionment fraction in 830 CMR 62.5A.1(5)(a), which decides how much of a nonresident employee’s salary Massachusetts gets. Gross income is multiplied by a fraction whose numerator is the number of days spent working in Massachusetts and whose denominator is total working days. Total working days excludes days the employee was not required to work, so holidays, sick days, vacations, and paid or unpaid leave come out of the denominator. A hybrid worker in the office two days out of five is looking at 40 percent of their wages as Massachusetts source income.

And then the sentence that quietly does the most work in this whole corridor. When a working day is spent working partly in Massachusetts and partly elsewhere, it will be treated as a day spent working in Massachusetts, unless the nonresident can prove that he or she worked outside Massachusetts for more than half the day. The default is Massachusetts. The exception is available, and it is conditioned on proof, and the proof has to be about a specific Tuesday eighteen months ago on which you answered email in Windham until eleven and then drove to a two o’clock in the Seaport.

Notice what the two counts have in common. Neither of them is satisfied by a New Hampshire address, a New Hampshire license, or a New Hampshire lease. Both are arithmetic performed on a record of your physical location, day by day, over a full year. And in both, the tie goes to Massachusetts unless you can show otherwise. A day count checker tells you where you stand against the 183-day line, which is the one that flips your entire filing status. The apportionment fraction is the one that quietly determines whether the move saved you 5 percent or 2 percent.

The practical consequence is that the commuter on this corridor needs a better presence record than the retiree on the Florida one, not a worse one. The retiree’s evidence problem is proving a change of life. The commuter’s evidence problem is proving the composition of roughly 240 individual working days, most of which looked like each other.

This corridor is also the one that produced the most consequential remote-work sourcing fight in the country, and the way it ended is widely misremembered.

In April 2020 Massachusetts adopted 830 CMR 62.5A.3, applying to the period commencing March 10, 2020 through 90 days after the governor gave notice that the state of emergency was no longer in effect. It provided that compensation earned by nonresidents who had worked in Massachusetts before the emergency but were telecommuting elsewhere because of it would continue to be treated as Massachusetts source income. Nonresidents could apportion using either the percentage of work days spent in Massachusetts from January 1 through February 29, 2020, or the apportionment percentage from their 2019 return if employed by the same employer. In plain terms, a New Hampshire resident working 100 percent of the time from a New Hampshire kitchen table was taxed by Massachusetts as though every day were a Boston day.

New Hampshire took it straight to the U.S. Supreme Court, seeking leave to file an original-jurisdiction complaint against Massachusetts. On June 28, 2021 the Court denied the motion. It did not decide that Massachusetts was right. It declined to hear the question, which left the constitutional issue open and the Massachusetts rule standing for the period it covered. The regulation itself expired on September 13, 2021, and physical-presence sourcing has governed since.

Then, in 2024, the Appellate Tax Board ruled on a taxpayer who had actually litigated it. Sakowski v. Commissioner of Revenue, Docket C347594, decided July 8, 2024, involved a New Hampshire resident and the 2020 tax year. The Board upheld the regulation. It rejected a Due Process challenge on the reasoning that Massachusetts had continued to confer benefits such as police, fire and road maintenance on the employer during the pandemic, and it rejected a Commerce Clause challenge citing South Dakota v. Wayfair for the proposition that physical presence is no longer the touchstone of constitutionality.

The rule that applies to your 2026 paycheck is physical presence. Days worked from a New Hampshire home are New Hampshire days and outside Massachusetts’s reach; days at a Massachusetts work site are Massachusetts days. That is the current law and it is favorable. But the history of this corridor is that when Massachusetts had a reason to source remote days to itself, it wrote a rule that did, the Supreme Court declined to stop it, and a state tribunal upheld it against both constitutional theories a taxpayer brought. The only thing that distinguishes a good year from a bad one under either regime is a contemporaneous record of where the work was performed.

Run the whole tax picture rather than the income line and the corridor gets more interesting. On the 2026 State Tax Competitiveness Index, New Hampshire ranks 3rd overall and Massachusetts ranks 43rd, and state and local tax collections per capita run 5,784 dollars in New Hampshire against 9,076 dollars in Massachusetts. That is the case for the move, and it is a strong one.

The offset is property tax. New Hampshire carries a 1.50 percent effective property tax rate on owner-occupied housing value, the highest in New England, against 1.00 percent in Massachusetts. That is not a rounding difference. On a 700,000 dollar house it is roughly 10,500 dollars a year against 7,000 dollars, and the New Hampshire figure is not an accident of local budgeting. New Hampshire has no income tax and no sales tax, so towns and school districts are funded almost entirely out of property. Massachusetts, for its part, levies a flat 6.25 percent sales tax with no local add-on, which is why the border retail strip exists.

For a household earning 200,000 dollars, the income tax saving is on the order of 10,000 dollars and the property tax offset on a comparable house eats a third of it. For a household earning 2 million dollars, the surtax alone changes the arithmetic so completely that the property line stops mattering. This corridor rewards income concentration more than almost any other, which is exactly what the IRS AGI flow shows: the number of movers grew modestly from 2019 to 2023 while the AGI they carried grew 66 percent.

Then there is the estate, which is the line item people on this corridor discover last. Massachusetts has an estate tax and New Hampshire has neither an estate tax nor an inheritance tax. Chapter 50 of the Acts of 2023 raised the Massachusetts filing threshold from 1 million to 2 million dollars, retroactive to deaths on or after January 1, 2023, and added a credit capped at 99,600 dollars to soften the cliff where crossing the threshold had exposed more than just the excess. Two million dollars is still a low threshold by national standards and there is no portability between spouses. It also reaches nonresidents who own Massachusetts real property, apportioned by the ratio of Massachusetts assets to the total. Keeping the Massachusetts house after the move does not just keep an abode-prong problem alive. It keeps a Massachusetts estate tax question alive for the rest of your life.

One more Massachusetts quirk worth pricing before a move rather than after: short-term capital gains, on assets held a year or less, are taxed at 8.5 percent rather than the 5 percent that applies to ordinary income and long-term gains, and the 4 percent surtax stacks on top, so a large short-term gain for a high earner can reach a combined 12.5 percent. New Hampshire now taxes none of it at any holding period. If your income includes active trading or a short-hold liquidity event, the delta on this corridor is materially wider than the headline 5 versus 0 suggests.

Because the two states are adjacent and the Massachusetts property market is what it is, an unusual share of movers on this corridor keep the old house. Sometimes it is a rental, sometimes a place for a kid still in school, sometimes it is just waiting for a better selling season. It is the single fact most likely to turn a clean move into a contested one.

A retained dwelling is the first half of the statutory residency test, and it is a fact that does not decay. It also anchors a domicile analysis, because DOR’s factor list opens with home purchase or lease, moved personal property, and sold Massachusetts real estate or canceled leases. Practitioners consistently flag not selling or renting the Massachusetts home as the pattern that draws the most scrutiny, followed by keeping Massachusetts bank accounts, safe deposit boxes, and club or church memberships active, and by continuing to file federal returns through the same IRS office. None of those are individually decisive. Collectively they read as a life that did not change.

Massachusetts also has a filing that catches people out in the other direction. Under M.G.L. c. 188 every Massachusetts homeowner gets an automatic 125,000 dollars of homestead protection with no filing at all, and recording a Declaration of Homestead at the county Registry of Deeds, Land Court Form 1, for a 36 dollar fee, raises that to 500,000 dollars, doubled to 1,000,000 dollars for elderly and disabled homeowners under the 2025 Affordable Homes Act. It is a creditor-protection instrument rather than a tax filing, and it is not income-tested or annually renewed the way New York’s STAR or New Jersey’s ANCHOR are. But it is a recorded, dated, public assertion that a Massachusetts property is your principal residence. Leaving one on the record while filing as a New Hampshire domiciliary is a contradiction sitting in a registry of deeds, and it is the kind of document a five-year records request finds.

The transition year is asymmetric in a way that is easy to misread as easy. On the Massachusetts side you file Form 1-NR/PY, the Nonresident/Part-Year Resident return, with Schedule R/NR to allocate income between the resident and nonresident portions of the year. On the New Hampshire side you file nothing. There is no individual income tax return of any kind, so there is no arrival filing, no part-year form, and no annual document that establishes when your New Hampshire life began.

That absence is the corridor’s real evidentiary problem. New Hampshire generates almost no dated paper about you. Its own definition of residency is behavioral rather than documentary: RSA 21:6-a defines residence as a person’s place of abode or domicile, designated as his or her principal place of physical presence to the exclusion of all others, and provides that it is not interrupted or lost by a temporary absence if there is an intent to return. RSA 21:6 adds that the person must have, through all of his or her actions, demonstrated a current intent to treat that place as their principal residence. An actions test, not a declaration test.

So the arrival record is whatever you deliberately create. Get the New Hampshire driver license and register the vehicles, both due within 60 days of establishing residency under RSA 261:45 and RSA 263:35, and keep the dated confirmations. Register to vote, which New Hampshire allows on Election Day itself with proof of domicile, and where a New Hampshire license, non-driver photo ID, or vehicle registration showing your domicile address each qualify as that proof. There is no declaration of domicile to file, no homestead exemption to apply for, and no annual property tax benefit that renews an assertion about where you live. New Hampshire’s Low and Moderate Income Homeowners Property Tax Relief program under RSA 198:57 refunds a portion of the State Education Property Tax only, and is capped around 20,000 dollars of AGI for a single filer and 40,000 for married or head of household, so for most movers on this corridor it does not apply and is not a domicile marker in any case.

There is also no reciprocity agreement between Massachusetts and New Hampshire, and there could not usefully be one, because reciprocity agreements resolve double taxation between two states that both tax wages. Here only one does. What that means practically is that a New Hampshire resident with Massachusetts work days files a Massachusetts nonresident return and gets no offsetting credit anywhere, because there is no New Hampshire return on which to claim one.

Set this against moving from Massachusetts to Florida and the contrast is documentary. Florida hands a mover an unusually complete evidence set almost as a byproduct of arriving: a declaration of domicile recordable under Fla. Stat. section 222.17, a homestead exemption application with a January 1 occupancy requirement and a March 1 filing deadline, a 30-day driver license rule and a 10-day vehicle registration rule. Every one of those creates a dated record with a government. New Hampshire hands you a 60-day license window and same-day voter registration. Distance does the rest of the work in the Florida case: nobody accidentally accumulates 184 Massachusetts days from Naples, and nobody keeps commuting to the Seaport from there. From Salem, New Hampshire, both are a normal Tuesday.

Set it against moving from New Hampshire to Massachusetts and the asymmetry reverses. Going south, you acquire a filing obligation, a day count that can make you a resident without your consent, and a state that will want five years of history if you ever try to leave again. Going north, you shed all of that on paper and none of it in practice, because the sourcing rules and the abode prong follow the facts rather than the address.

Which is the honest summary of this corridor. The tax delta really is the cleanest in the country, and it is the part of the analysis that requires no work at all. What requires work is everything the delta does not touch: the equity you earned over a decade in Massachusetts, the office days that still source wages to Massachusetts, the house you did not sell, the estate that still has Massachusetts real property in it, and the two separate day counts that both start from the assumption that the day was a Massachusetts day.

The Mobility Map records days and nights by state as they happen, which on this corridor answers two questions rather than one: how the year stands against the 183-day statutory line under section 1(f), and what the working-day composition looks like for the 830 CMR 62.5A.1(5)(a) apportionment fraction. Those are different counts on the same underlying record, and both of them default to Massachusetts when the record is thin.

Evidence Vault holds what this corridor actually asks for: the closing statement or lease termination on the Massachusetts property, the discharge of any recorded Declaration of Homestead, the New Hampshire license and vehicle registrations with their dates, the voter registration, the Form 1-NR/PY and Schedule R/NR for the transition year, employer records or badge data supporting which days were worked where, and the equity documents, grant agreements and repurchase paperwork that determine whether a future liquidity event is Massachusetts source income under section 5A. AuditIQ surfaces retained Massachusetts ties that keep generating dated records in a state whose Department of Revenue asks for five years of address history, day-by-day presence records, and the IRS office where federal returns were filed. Advisor sharing lets a CPA or tax attorney review the presence record, the wage apportionment and the Massachusetts-source items together, since only the first of those responds to the move.

ResidencyIQ organizes records and highlights potential exposure factors. It is not a law firm or an accounting firm and does not provide legal or tax advice; work with a qualified CPA or tax attorney on your own domicile, filings, and state exposure.

The two-prong definition of a Massachusetts resident or inhabitant, covering a person domiciled in the commonwealth and a person not domiciled there who maintains a permanent place of abode and spends in the aggregate more than 183 days of the taxable year in the commonwealth including days spent partially in and partially out, together with the armed forces exclusion, is M.G.L. c. 62, section 1(f): https://codes.findlaw.com/ma/part-i-administration-of-the-government-ch-1-182/ma-gen-laws-ch-62-sect-1.html/. The Department of Revenue definition of a permanent place of abode as a dwelling place continually maintained by a person whether or not owned by that person, including a dwelling owned or leased by a spouse, and the exclusions for a college dormitory, hospital room, military barracks, seasonal camp and temporary stay for a specific limited purpose lasting less than a year, are from TIR 95-7, Change in the Definition of Resident for Massachusetts Income Tax Purposes: https://www.mass.gov/technical-information-release/tir-95-7-change-in-the-definition-of-resident-for-massachusetts-income-tax-purposes. The DOR domicile definition, factor list and documentation requests, including five years of address history, months per year at each location, property ownership records in every state, voter registration history and the IRS office where federal returns were filed, are from Legal and Residency Status in Massachusetts: https://www.mass.gov/info-details/legal-and-residency-status-in-massachusetts.

Welch v. Commissioner of Revenue, No. 24-P-109 (Mass. App. Ct. April 3, 2025), affirming the Appellate Tax Board decision of November 29, 2023, is the source of the case narrative: the 2005 founding of AcadiaSoft and the founder’s stock, Welch’s roles as founder, president, treasurer, clerk, director and CEO, the eighty-hour weeks, the reported wages of zero for 2003 through 2005, 5,533.77 dollars in 2006 and 7,235.42 dollars in 2007, the 11.86 percent shareholding, the April 30, 2015 move to New Hampshire as the last day of Massachusetts residency, the June 29, 2015 repurchase for cash proceeds of 4,744,759.96 dollars against a zero basis, the 335,968.62 dollars of assessed tax, interest and penalties, the statement that the commissioner does not argue that Welch’s domicile was Massachusetts at the time of sale, the 830 CMR 62.5A.1(3)(c)(8) general rule for C and S corporation stock and its compensation-for-services exception, the finding that the stock was compensatory because his wages were not commensurate with the effort expended, and AcadiaSoft’s apportionment of all income to Massachusetts on its corporate excise returns: https://caselaw.findlaw.com/court/ma-court-of-appeals/117127326.html and https://law.justia.com/cases/massachusetts/court-of-appeals/2025/24-p-109.html. The 2003 amendment to G.L. c. 62, section 5A(a) adding gain from the sale of a business or of an interest in a business, the standard of review giving some deference to the Board’s expertise, and the planning commentary are from Current Federal Tax Developments: https://www.currentfederaltaxdevelopments.com/blog/2025/4/5/massachusetts-source-income-and-the-sale-of-stock-by-a-nonresident-a-deep-dive-into-welch-v-commissioner-of-revenue, with additional practitioner analysis from Mintz: https://www.mintz.com/insights-center/viewpoints/2226/2025-07-17-navigating-massachusetts-taxes-after-relocation-key and RSM: https://rsmus.com/insights/tax-alerts/2025/massachusetts-court-affirms-tax-due-on-nonresidents-capital-gain.html.

The nonresident working-days apportionment fraction, the exclusion of holidays, sick days, vacations and paid or unpaid leave from total working days, the rule that a working day spent partly in Massachusetts and partly elsewhere is treated as a Massachusetts working day unless the nonresident can prove he or she worked outside Massachusetts for more than half the day, the 830 CMR 62.5A.1(3)(c)(8) treatment of C and S corporation stock gain, and the 830 CMR 62.5A.1(3)(c)(7) treatment of deferred compensation are all in 830 CMR 62.5A.1, Non-resident Income Tax: https://www.law.cornell.edu/regulations/massachusetts/830-CMR-62-5A-1.

The COVID-era telecommuter sourcing rule, its application to the period commencing March 10, 2020 through 90 days after the governor’s notice that the state of emergency was no longer in effect, the treatment of pre-emergency Massachusetts work as continuing Massachusetts source income, and the two permitted apportionment methods based on the January 1 through February 29, 2020 work-day percentage or the 2019 return’s apportionment percentage, are 830 CMR 62.5A.3: https://www.law.cornell.edu/regulations/massachusetts/830-CMR-62-5A-3. The U.S. Supreme Court’s June 28, 2021 denial of New Hampshire’s motion for leave to file an original-jurisdiction complaint in New Hampshire v. Massachusetts, which left the underlying constitutional question undecided, is covered by Eversheds Sutherland: https://www.eversheds-sutherland.com/en/united-states/insights/scotus-denies-new-hampshires-motion-challenging-massachusetts-taxation-of-nonresident-remote-workers. Sakowski v. Commissioner of Revenue, Appellate Tax Board Docket C347594, decided July 8, 2024, upholding the regulation for the 2020 tax year against a New Hampshire resident’s Due Process challenge on the ground that Massachusetts continued to confer benefits such as police, fire and road maintenance on the employer, and against a Commerce Clause challenge citing South Dakota v. Wayfair for the proposition that physical presence is no longer a touchstone of constitutionality, is reported by Eversheds Sutherland’s SALT Shaker: https://www.stateandlocaltax.com/income/massachusetts-atb-upholds-income-tax-on-pandemic-era-telecommuter/.

The repeal of the New Hampshire Interest and Dividends Tax effective January 1, 2025 under House Bill 2, the rate step-down from 5 percent to 4 percent for taxable periods ending on or after December 31, 2023 and to 3 percent for periods ending on or after December 31, 2024, and the instruction that 2025 estimated payments should not be filed and 2025 returns are not required, are from the New Hampshire Department of Revenue Administration: https://www.revenue.nh.gov/news-and-media/repeal-nh-interest-and-dividends-tax-now-effect, with the 1923 enactment date and practitioner commentary from McLane Middleton: https://www.mclane.com/insights/nh-interest-and-dividends-tax-repealed-as-of-january-1/. The RSA 21:6-a definition of residence as the place of abode or domicile designated as a person’s principal place of physical presence to the exclusion of all others, not interrupted by a temporary absence where there is an intent to return, and the RSA 21:6 requirement that the person have through all of his or her actions demonstrated a current intent, are at https://gc.nh.gov/rsa/html/I/21/21-6-a.htm and https://gc.nh.gov/rsa/html/i/21/21-6.htm.

The Massachusetts 2026 surtax threshold of 1,107,750 dollars under M.G.L. c. 62, section 4(d) as adjusted for inflation, alongside the prior thresholds of 1,083,150 dollars for 2025, 1,053,750 dollars for 2024 and 1,000,000 dollars for 2023, is published by the Department of Revenue at https://www.mass.gov/info-details/massachusetts-4-surtax-on-taxable-income. The 5 percent flat rate with a 9 percent top rate including the surtax, the 6.25 percent sales tax with no local add-on, the 1.00 percent effective property tax rate on owner-occupied housing value, state and local collections of 9,076 dollars per capita, and the 43rd place ranking on the 2026 State Tax Competitiveness Index are from the Tax Foundation: https://taxfoundation.org/location/massachusetts/. New Hampshire’s absence of any wage or investment income tax, absence of a state sales tax, 1.50 percent effective property tax rate on owner-occupied housing value, 5,784 dollars per capita in state and local collections, absence of an estate or inheritance tax, and 3rd place ranking on the same index are at https://taxfoundation.org/location/new-hampshire/.

The Massachusetts estate tax changes under Chapter 50 of the Acts of 2023, raising the filing threshold from 1 million to 2 million dollars retroactive to deaths on or after January 1, 2023 and adding a credit capped at 99,600 dollars to mitigate the cliff effect, and the application of the threshold to nonresidents owning Massachusetts property, are described by Nixon Peabody: https://www.nixonpeabody.com/insights/articles/2023/10/04/massachusetts-estate-tax-exemption-2000000-as-of-january-1-2023 and the Boston Bar Association: https://bostonbar.org/journal/what-to-know-about-the-recent-change-to-the-massachusetts-estate-tax/. The Massachusetts 8.5 percent short-term capital gains rate against the 5 percent rate on ordinary income and long-term gains, and the combined 12.5 percent that results once the surtax applies, are from Taxstra: https://taxstra.com/massachusetts-capital-gains-tax/. The automatic 125,000 dollar homestead protection, the 500,000 dollar declared homestead under M.G.L. c. 188 recorded on Land Court Form 1 for a 36 dollar fee, and the doubling to 1,000,000 dollars for elderly and disabled homeowners under the 2025 Affordable Homes Act are from Deeds.com: https://www.deeds.com/articles/in-case-you-missed-it-massachusetts-affordable-homes-act-doubled-homestead-exemption-to-1-million/.

The migration figures come from the Josiah Bartlett Center for Public Policy. The Census-based counts of 369,368 Massachusetts residents moving to New Hampshire and 223,720 moving the other way from 2005 to 2024, for a net of 145,648, are at https://jbartlett.org/2026/03/massachusetts-lost-145000-residents-to-new-hampshire-over-the-last-20-years/. The IRS return and AGI figures, including 10,603 returns moving to New Hampshire against 6,594 to Massachusetts for 2023, the 1.4 billion dollar inflow against a 557,595,000 dollar outflow for a net gain of 870,606,000 dollars, the 5.95 billion dollar net AGI gain from 2012 through 2023, and the observation that AGI moving north grew 66 percent from 2019 to 2023 against 32 percent moving south, are from IRS data analyzed for the Center by the Pioneer Institute: https://jbartlett.org/2026/04/mass-refugees-have-brought-6-billion-in-personal-income-to-nh-since-2012/.

The Massachusetts and New Hampshire exit stickiness and audit aggressiveness ratings, the description of DOR placing the burden of proving a domicile change on the taxpayer and requesting an unusually large volume of documentation once a nonresident return follows a history of resident filing, the enforcement method inventory, the Form 1-NR/PY and Schedule R/NR part-year filing mechanics, the commonly missed exit mistakes including not selling or renting the Massachusetts home and continuing to file federal returns through the same IRS office, the New Hampshire 60-day license and vehicle registration deadlines under RSA 261:45 and RSA 263:35, the same-day voter registration rule and its accepted proofs of domicile, and the RSA 198:57 Low and Moderate Income Homeowners Property Tax Relief program and its income caps come from ResidencyIQ’s own dossier research, with underlying citations on the Massachusetts and New Hampshire residency guides.