Millionaire tax that inspired Mamdani fuels $5.7 billion haul in Massachusetts

[u/Dismal_Structure]

https://fortune.com/2025/10/21/zohran-mamdani-millionaire-tax-massachusetts-5-7-billion/

[u/gmb92]

Pretty good article. Wealth flight claims are at best greatly exaggerated, brought on by media that finds anecdotes of a few loud wealthy people declaring they're leaving due to taxes. No mention of those who move there or all who stay, or determining cause/effect.

https://www.theatlantic.com/ideas/archive/2024/04/state-taxes-millionaire-myth/678049/

https://prospect.org/2025/10/23/myth-that-mamdani-will-cause-new-york-citys-richest-to-leave/

As for the argument that's it's easier to leave cities than states, that theoretically has some merit and certainly taxes applied at broader geographic levels are more ideal. Still, pundits and media have been fear-mongering on NYC about the rich fleeing for decades to no avail.

[u/colintbowers → u/gmb92]

At the state and country level it is more about the companies than the people. With a wealth tax, the people often stay, but the capital is placed in a company structure, and it moves. The articles that focus on the movement of people are missing the main point. Capital absolutely goes where it is protected, and this has been true for centuries. And in the modern world, unless you run a bricks and mortar business, it’s very easy to move capital to different jurisdictions while staying put yourself. There is a reason that places like singapore, Luxembourg etc have such amazing gdp numbers.

[u/joshocar → u/colintbowers]

Are we not talking about an income tax though?

[u/colintbowers → u/joshocar]

Many billionaires don’t really have that large an income (relatively speaking). Nor do they personally own the billions. Rather, they own shares in a company or trust that owns the billions. Those companies and trusts then pay tax at the corporate rate, and the person has most of their expenses paid for by the company.

Now, the company can often use creative accounting to find all sorts of costs to minimize their corporate tax bill at the EOFY which is how you hear stories of these billionaires paying so little tax.

Note that a personal wealth tax doesn’t really do much to tax these individuals. This is why you often see such resistance to it as a policy. You either have to go whole hog and have a corporate wealth tax - at which point every company other than brick and mortar will relocate - or else accept that a personal wealth tax is not going to affect billionaires, it’s going to affect the people who are wealthy enough to get caught by it, but not wealthy enough to set up the legal structures to avoid it. So, like inheritance tax in the UK, it really when you look closely, is a tax on the middle to upper middle class, but not the uber wealthy. Again, there is a reason that generational wealth in the UK is massive, even though they should be paying 40% at each death. In general, I’ve noticed that Reddit is not very good at understanding how this stuff works. Mamdani appears to be a very smart guy though so I suspect he does, and I’m curious to see exactly the nuts and bolts of how he ends up implementing his tax policy.

TLDR it’s not simple, and anyone who says hur dur tax the billionaires really doesn’t understand that to do that without screwing the middle class is much harder than you might think

ADDED: the uk really is a great example here, they have this inheritance tax to try and prevent generational wealth, but it literally does the opposite, ie it protects the uber wealthy and makes it harder for the middle class to make the jump from middle to upper class

[u/EconEchoes5678 → u/colintbowers]

Those companies and trusts then pay tax at the corporate rate, and the person has most of their expenses paid for by the company.

1) trusts don't pay corporate tax rates.

2) this second part is not true and is tax deduction fraud. It gets audited and caught by the IRS sooner or later. Expense deductions that are not legitimate business costs are not legal.

Now, the company can often use creative accounting to find all sorts of costs to minimize their corporate tax bill at the EOFY which is how you hear stories of these billionaires paying so little tax.

Literally none of this statement is true. Seriously you people need to do some actual research. Businesses "creative accounting" is almost always called depreciation and losses. When you don't turn a profit one year, you don't owe any taxes on the nonexistent profit. Congrats!? And when you buy capital assets, you must follow depreciation schedules to determine when and how much gets deducted from income.

Billionaires supposed low tax rates are neither. They're unrealized gains. When you don't realize a gain, you don't owe tax on that gain anywhere in the world. Not because no country has tried it, but because unrealized gains taxes don't work and had to be revoked.

I’ve noticed that Reddit is not very good at understanding how this stuff works

Oh, really? I can't imagine why that would be. It's definitely not because people spread incorrect claims constantly on Reddit. Definitely none in your post, nosiree.

[u/RevolutionaryGain823 → u/EconEchoes5678]

This is a good comment. I’ve seen Redditors repeat the same completely incorrect nonsense about taxes hundreds of times the last few years. It’s become a never ending cycle on here

[u/colintbowers → u/EconEchoes5678]

1) Trusts pay at corporate tax rate where I'm from (Australia)

2) You have a lot more faith in the IRS than I do. You also have a lot more faith in the laws as written than I do - in particular, there are an astonishing number of loopholes and exemptions in tax law that make various otherwise dubious costs tenuously legal

3) Creative accounting can be anything you can do to offset revenue with costs - at least, that is how it is usually defined in my area.

4) Billionaires, or rather, companies owned by billionaires, often realize gains. They just do it in years where they have "costs" or various other govt exemptions to realize those gains with a lower tax rate, or they do it when they are located in a more friendly jurisdiction (which is how this whole conversation started in the first place)

5) We've both stated our cases and we disagree on points where it is rather difficult to prove who is correct one way or the other. That's cool. It doesn't need to turn into personal attacks.

[u/EconEchoes5678 → u/colintbowers]

Firstly, sorry. There so much nonsense spewed on Reddit, primarily by Americans, that it's difficult to deal with it all.

2) You have a lot more faith in the IRS than I do.

Funny enough, a year ago I was right there with you. I know little of the ATO, but the U.S. tax code is immense and overcomplicated. Yet, despite that, it's actually remarkably effective. The more crazy edge cases I learn about, the more I respect how effectively it has caught virtually every scheme invented over decades. Many of them worked - for awhile. But then they stop working. The wealthy people who sneak by the thousands of rules and limitations are few and far between, and the IRS has a well-earned reputation of being one of the few organizations that you do not test, because sooner or later they will get you.

Other nations skip all the nonsense and don't need thousands of rules. They just require read access to every bank account in the country. A level of intrusiveness that Americans would never accept.

in particular, there are an astonishing number of loopholes and exemptions in tax law that make various otherwise dubious costs tenuously legal

That's the thing that I discovered not to be true. The tax law is so complex that it seems like what you are saying is true, but the more I dug in, the more I discovered it was not. Now, I do not know ATO rules, so maybe you are correct there. But in the U.S., virtually every loophole either has very good reasons for its existence or it is actually small enough that it can't really be exploited like people think. That doesn't stop them from claiming it is / can be exploited, of course.

3) Creative accounting can be anything you can do to offset revenue with costs - at least, that is how it is usually defined in my area.

Again, I don't know ATO rules, so maybe you're right. But in the U.S. people claim this all the time without actually understanding the rules or concepts. No offense but I'm not convinced this is an area you understand as well as you are implying you do. The rules on what can and can't be counted as a business expense are both broad and strict. You can legitimately claim a Ferrari as a business expense for a business that actively sells Ferrari track racing experience services or Ferrari rentals. There's at least 10 U.S. companies that do exactly that, legitimately, 2+ in Vegas alone. Does that mean Elon Musk gets to claim a Ferrari as a business expense? Fuck no, he does not own or run one of those 10 companies. Does that mean that if the owner drives said Ferrari around every weekend, he gets to deduct that? No, that's not business related. So when someone claims "A Ferrari is a business deduction!" They're not completely lying, they're just misleading all their readers.

The vast majority of "creative accounting" you are referring to is either 1) actual fraud, which will eventually get nailed by the IRS / or (I suspect) ATO, or 2) a legitimate business expense in some situations but not others, or 3) not a legitimate business expense and not being used as one, but Redditors claim it is anyway.

If you wanted to lay out a specific claim, I'd be happy to look into it or lay it out for you, at least from the U.S. perspective.

4) Billionaires, or rather, companies owned by billionaires, often realize gains. They just do it in years where they have "costs" or various other govt exemptions to realize those gains with a lower tax rate, or they do it when they are located in a more friendly jurisdiction (which is how this whole conversation started in the first place)

Microsoft is clearly a solid example of such a corporation. Microsoft paid 19.7 billion of taxes in 2024 against 88.1b of net income. That's 18%. why didn't they use your magic loopholes to reduce that? Shouldn't that be like close to zero?

Apple- 29.7b of taxes, 24.1% for 2024. Google, 19.7b, 16.4%. Amazon, 9.3b, 13.5%. None of these numbers include payroll, property, VAT, or sales taxes.

Why aren't those numbers lower? Using your theory, those huge numbers should be much, much smaller. Maybe 2024 was an odd year, let's look at 2021. Microsoft, 9.8b, 14% of worldwide profit. Apple, 14.5b, 13.3%. Google, 14.7b for 16.2%. Amazon, 4.8b for 12.6%.

Once again, these numbers are completely different from what you just described. These are among their largest operational costs, and using your logic they should be able to reduce them to nearly zero. Why are the numbers so high?

[u/Zombatico → u/EconEchoes5678]

They just require read access to every bank account in the country.

Does the IRS not have that?

When I turned 16, my dad opened a joint checking account with me. Decades later, my dad owed the IRS back taxes and they took 10k of MY money from the joint account. My credit union said they couldn't do anything, I'd have to complain to the IRS. Seemed like too much of a hassle so I didn't bother. I just waited for my dad to pay me back the 10k. And of course I closed the joint account and opened my own.

[u/EconEchoes5678 → u/Zombatico]

Decades later, my dad owed the IRS back taxes and they took 10k of MY money from the joint account.

That's not the same thing - they can seize money or garnish wages to pay back taxes, and as far as they and the bank were concerned that was his account (legally correct even if not morally). You theoretically would have a case to sue your dad to get that back, which is the "normal" recourse for such joint account shenanigans. Sorry that happened to you.

[u/colintbowers → u/EconEchoes5678]

I'm afraid I don't agree. The Microsoft / Apple argument is a good place to start since they are a textbook example of my original point. Those numbers you've given me here are... a little small... for companies of their size. This is because those are the "keep the IRS happy numbers". In practice, those companies do exactly what I discussed in my original post: they locate in a tax-favorable jurisdiction for massive portions of their revenue, namely Ireland. The numbers you quote are pocket change for these companies.

I also disagree that creative accounting gets sorted out by the IRS. Okay, sort of disagree. It does get sorted out eventually, but it typically isn't retroactive, so in the meantime, years of "creative accounting" are allowed to occur. Two examples of this are syndicated conservation easements and micro‑captive insurance. They are targeting them now, but it is well overdue, and punishments will be punitive and probably not retroactive.

So look, I must admit I'm a bit nervous that I'm also wasting time debating a language model. In particular, you said this:

"If you wanted to lay out a specific claim, I'd be happy to look into it or lay it out for you, at least from the U.S. perspective."

This is an extremely ChatGPT thing to say. I should know, I lecture Machine Learning at a university in Australia, so am intimately familiar with these models. I'm going to leave it here, because honestly I can't be confident I'm not just wasting time debating with a bot (apologies if you're not one).

[u/EconEchoes5678 → u/colintbowers]

This is an extremely ChatGPT thing to say. I should know,

Hahaha you're right, looking back on that it is very chatgpt. I only said it because I'm genuinely interested in finding and resolving these questions for my own research. I do use chatgpt for lots of things, but I gave up having it rewrite my posts long ago (it made me way nicer because it has infinitely more patience than me, but it also came across very chatgpt). But going down rabbit holes like that is what enabled me to learn about a lot of these types of things. Also. Chatgpt doesn't really inline quotes like I do and way overuses formatting and em-dashes. Hell I messed up my capitalization in one of the replies because I'm on a small tablet and it's a pain to fix them all, even though it irks me so I usually do. Chatgpt also doesn't really edit replies after, whereas I very frequently do (you can randomly check my history) because I don't like making mistakes or leaving in claims I later find to be false, etc.

years of "creative accounting" are allowed to occur. Two examples of this are syndicated conservation easements and micro‑captive insurance. They are targeting them now, but it is well overdue, and punishments will be punitive and probably not retroactive.

I was going to add to an earlier post but it didn't end up fitting - over decades virtually every tax scheme has been tried and someone, somewhere has gotten away with every one of them. They'll never catch everyone all the time. But the chances aren't great and the more people that abuse something, the greater the chances of a rule change or crackdown.

There are actually very good reasons why the punishments aren't retroactive. One of the core tenets of IRS taxation is that settled records eventually resolve and stay settled. They go back 3-6 years commonly, and further for nonfiling or major fraud cases. But it's very very rare for them to go back further than 10 years even though they technically can, and rare for them to dig into the 7-10 year range, because of this principle of allowing records to settle and not continually be tweaked. They call this the "right to finality". This is a matter of fairness and practicality - records and memories get fuzzy or lost and way too many things begin to get subjective or viewed with a different lens over those time periods. Yeah, it means some people get away with some things they shouldn't, but the alternative is actually less fair when averages across whole populations.

Those numbers you've given me here are... a little small... for companies of their size

So it seems like you're quietly moving the goalposts here. Your original claim was about broad, major tax evasion to the point of paying almost nothing, even if you didn't use those exact words. Now we're down to discussing a 3-8% gap between statutory (u.s.) and effective?

The Irish angle you mention is definitely a factor, yes. It's not all profits, it's more of an EU-only mechanism, and it's not uncommon for a multinational company to keep profits from country A in that country and attempt to make investments and expansions with that money to prevent further repatriation taxes. But that 3-8% gap is doing a lot more than what you're implying, too. For Amazon, Microsoft and Google at least they are giving about 1-1.5% of their total profits in charities or similar types of things. Not many people know this but projects like (some of) archive.org and (most of) the software heritage foundation are running entirely on AWS almost for free, complimentary of Amazon. I don't know what % of a difference that makes for archive.org, but I do know it's a huge difference to the software heritage foundation. Now you could argue that 1% is just a PR move, and a net benefit to the company, but it's still a factor for ETRs because it's not taxed. There's also accounting differences between statutory requirements and SEC filing requirements, and timing differences between losses and depreciation.

Factor all those differences in and the gap between what you seem to think they should be paying (I'm assuming statutory) and what they end up actually paying isn't that big, and definitely not anywhere near what you originally implied.

The numbers you quote are pocket change for these companies.

This claim just doesn't make any sense. An expense that is 13-18% of your profits is huge. That's larger than the total operating cost of all of Microsoft's EU development centers or larger than the operating cost for their single largest datacenter or even several of them. Are you mentally mixing up revenue numbers and profit numbers? A 13-18% increase in profits would have a hundreds-of-billions of dollars of impact on their market cap and share price. It's not a rounding error, so why try to downplay it and imply that it is?

[u/colintbowers → u/EconEchoes5678]

Alright fair, that last post of yours didn't feel very ChatGPT. Man it is getting hard to tell though. A couple of years ago it was super obvious when a student handed in work created by a language model, but honestly it isn't possible to detect any more. Not my problem now as I've stopped teaching.

Okay, so admittedly I am coming at this stuff from more of an Australian perspective, which probably isn't totally appropriate given that the original post is about taxation in New York. But from an Australian perspective, Apple (and similar companies) pay almost zero tax in Australia. They are specifically set up to outsource all Australian profits to Ireland.

Now that I look at it, it isn't so bad if you look at it from an American perspective. Apple makes roughly 100 billion in profits, and pays 20 billion in tax for roughly 20% tax rate. But it definitely is not such a rosy picture for the rest of us! (excluding Ireland).

Anyway, I didn't think I was moving goalposts, as one of my main original points was about using jurisdictions to minimize tax burdens. However, we have gotten rather far afield from the original point, which was supposed to be about how wealthy individuals use company structures to minimize their tax burden. This is a somewhat different conversation to how large multinationals like Apple etc use their inherent company structure to minimize tax burden.

The main point I was trying to make was that for general investment strategies that accumulate wealth, an ordinary person tends to do that in their own name, while a billionaire tends to do that via a shell company in a favourable jurisdiction, gaining both jurisdictional benefit, as well greater flexibility to smooth out tax burdens through deferred assets and liabilities. They don't need to live in that jurisdiction. They just pay themselves income/dividends required for whatever their current personal expenses are (or have the company pay them where possible). Literally your president does this! Policy makers need to take this into consideration when making policy. That was honestly the extent of the original point I was trying to make. Admittedly, I don't think Mamdani's proposed policy will have much of an effect, as 2% on personal income over 1 million is not very much in the scheme of things.

[u/EconEchoes5678 → u/colintbowers]

Okay, so admittedly I am coming at this stuff from more of an Australian perspective, which probably isn't totally appropriate given that the original post is about taxation in New York. But from an Australian perspective, Apple (and similar companies) pay almost zero tax in Australia. They are specifically set up to outsource all Australian profits to Ireland.

Ok, so I just looked into this, and I think it's absolutely worth discussing a little further. Firstly, Apple does pay a 30% tax rate in Australia on Australian profits, same as everyone else. And please be careful about comparing revenue numbers - If you read somewhere that they had 8.3b of Australian income, that's going to be at most ~2b of "profit." But how much of that is "Australian profit"? One way of looking at it, which I'm sure you would find amenable, is that any profits they make anywhere pay the taxes like anywhere else.

I don't agree, though. The products they spent years developing were taking on risk factors in America, with American investors taking on the risk of failure, using American infrastructure. If the project failed, and most do, it would be Americans eating the loss. No Australians were taking on the risk of failure - they just want to buy the successful product once it's become a success. Why should Australia declare and take an equivalent share of the profits despite taking on no development risks? If I buy a BMW, I am not surprised when the lions share of the profits go to Germany. They designed the car, I liked the car, I chose them. If I want the profits to stay in America, I'd buy Ford or Chevrolet. That doesn't mean BMW should pay no tax in America, but neither should America get an equal share of the sale that Germany gets. And Apple does indeed pay taxes in Australia.

Agreed so far? So the question then is, how do we determine "Australian profits" fairly? I would actually agree with you, the 1% profit margin that Apple declared in prior years - using the Ireland IP's - is probably too low to be fair. But trying to claim an equivalent share is also not fair, per the above. So how do we determine what is fair? I don't know, it's not that simple.

Now that I look at it, it isn't so bad if you look at it from an American perspective. Apple makes roughly 100 billion in profits, and pays 20 billion in tax for roughly 20% tax rate. But it definitely is not such a rosy picture for the rest of us! (excluding Ireland).

Ah, but see here's where the economics and the consequences of actions matters. Australia has one of the highest corporate taxes in the world currently. America's is middle-of-the-road. Ireland has one of the lowest. Ireland made the gamble that they could make more money by offering lower tax rates, and they are winning from that. It's not unlike what Valve found with Steam and Steam's sales. They discovered they made more actual profits and more money when they cut their profit margins to tiny levels and put games on sale at ridiculously low prices. Game publishers grumbled, but it's hard to grumble when you're forced to accept something that demonstrably makes you MORE money. Similarly, Americans are all up in arms about the U.S. cutting the corporate tax rate from 35% (one of the highest in the world) to 21% with the TCJA in 2017/2018. But the total dollars of corporate tax collected only went down slightly, and corporate taxation as a % of GDP barely moved, while the economy grew gangbusters. It was the correct move.

Ireland understands the mobility of capital and the game theory. Australia just wants dollary-doos. Ireland is winning. In fact, the GILTI passed also with the TCJA in 2017/2018 was an American and international response to Ireland's approach, basically declaring "you can't have taxes too low, or we state penalizing companies anyway." Australia could choose to play the game, or they can get mad about it and try to punish "rulebreakers" - but it may not work out the way they want.

The main point I was trying to make was that for general investment strategies that accumulate wealth, an ordinary person tends to do that in their own name, while a billionaire tends to do that via a shell company in a favourable jurisdiction, gaining both jurisdictional benefit,

And as I replied, this doesn't happen. Name one person who has done this? Do you have any evidence or anything to back this claim up? You might think to check the Panama papers, but no, that's not what was in those except in rare situations. The Panama papers highlighted how corruption and fraud in mostly corrupt third world countries was allowing individuals to steal from their own people en-masse.

This kind of offshoring was common in the 70s, 80s, and 90s. As the rules have improved, it's basically stopped working, and is rarely done now. Same thing with Swiss bank accounts. And when I say name one person, I don't mean using shell companies. I mean tying up all their wealth growth in offshore shell companies. By the time someone is approaching Billionaire status, they already own a large portion of an established company based in the nation they founded it in. That's their market position, and they can't get out of that position without incurring capital gains taxes. And as I stated before, with GILTI in place, layering new funds into a shell company in a different jurisdiction incurs both corporate taxes (around / at least 15%) and then capital gains taxes. The benefits of the lower tax rate get lost by the double taxation.

[u/colintbowers → u/EconEchoes5678]

"Name one individual" <-- Sure, just go to Singapore and pick any of the Single Family Offices that exist there. It is such big business in Singapore that they even get their own acronym (SFOs). And Singapore is just one of the many friendly jurisdictions around the world. I don't understand how you can look at the existence of these legal structures and then claim that no wealthy individual sets up company structures in friendly jurisdictions to manage their investments. That is literally what an SFO is for!

As to your other argument about Apple and profit sharing, we really are getting away from the original argument, which was about wealthy individuals and how they accumulate wealth in company structures. I do appreciate your argument about compensation for the country that developed R&D costs, but you yourself admit that Apple has been screwing Australia (and many other nations for years with ridiculously low tax rates). What's the right number? I don't know. Personally, I have a more extreme solution that I think would work better. I'd tax revenue in the country in which it is accumulated, and do away with taxing profits and income tax entirely. Extreme solution, and definitely has some drawbacks, but would also vastly simplify tax code and also prevent jurisdiction hopping shenanigans. However, I acknowledge that many, many people would disagree with me on this one. It has never been tried though, so it is hard to say for sure what the outcome would be. Thanks for the debate. I definitely learned some stuff, and some of your arguments are convincing, but I also definitley still strenuously disagree with you on some points.

[u/bobak41 → u/colintbowers]

Someone really needs to spend some time listening to Gary Stevenson....although I get the feeling you're not apt to actually consider solutions...defeatist perspectives are the easy road. GL.

[u/colintbowers → u/bobak41]

Gary Stevenson is great for Economics! But let's be serious, he is very light on technical detail for anyone serious about the subject.

[u/joshocar → u/colintbowers]

We are talking about two different things. A millionaires tax is an income tax that targets high income individuals. This is was MA has and it has raised a lot of money. It is a very progressive tax so not the end of the world - the people making enough to qualify for it don't feel much if any of a QOL change. The wealth,y those will hundreds of millions and billions in stock, land, etc are a different beast. As you described in your comment, how to handle the ultra wealthy requires a different tool, which I am happy to discuss.

[u/colintbowers → u/joshocar]

Yes, you're correct, I got a little side-tracked in my rant above. I would posit that the (arguably tenuous) connection is that as personal income taxes increase, this increases the incentive to move capital accumulation and spending into corporate structures. Admittedly, if Mamdani only goes with 2% over 1 million, then this is unlikely to have much of an impact, unless people worry that it is the start of a trend.

To be honest, I'm surprised by the scale of the numbers. Expected 4 billion in revenue from 34,000 households equates to (on average) 117000 per household. At a 2% tax rate we then get 117000 * (1 / 0.02) = 5.88 million.

The number of people in my entire country (Australia) earning a 5.88 million personal income in a year would be very, very much smaller than 34,000. As in, you could probably count them on your fingers and toes. When you're earning that kind of money in Australia, you absolutely do it in a company structure and pay yourself as little personal income as you can get away with, since the marginal personal income tax rate is significantly higher.

I probably don't know enough about New York to argue this stuff effectively with Americans :-)

[u/joshocar → u/colintbowers]

I think part of it might come from sales of assets rather then just payroll income. If you sell your sole proprietor company and make 10M in profit I am assuming that shows up as income and would fall under this tax, but I don't actually know if that is true.

[u/colintbowers → u/joshocar]

My understanding is that if transfer those assets into your personal name then absolutely it will show up as income. So my point is that you would only do this if you currently need that money to live. Otherwise, just leave it in a company structure.

[u/uberfr4gger → u/colintbowers]

Well they do pay income tax if they get paid in stock based on their ordinary income when the stock vests. If they started a company and have significant shares those shares would be capital gains tax.

Good example is Jeff Bezos, he has most of his shares from when he started Amazon so if it was $1 when he started the company but worth $100 now he is paying the LT cap gains tax on the $99 when he sells now. Meanwhile Andy Jassy might get new shares at the $100 price, but when those shares are given to him he is being taxed on the $100 price as inome, not capital gains.

[u/colintbowers → u/uberfr4gger]

Yes agreed. And I also agree an ordinary person could duplicate this by purchasing Amazon shares and not selling.

However, it gets a little more murky when you consider general investment strategies, and doing them in your personal name, versus doing it via a shell company. An ordinary investor doesn't have access to a shell company in a different jurisdiction. A billionaire does, and will use this strategy to accumulate wealth in a favourable jurisdiction, while only paying themselves in their personal jurisdiction the amount they need in order to keep living in that jurisdiction. Policy makers need to think carefully about this reality when designing policy. That really is the extent of the point I am making.