Important Unexpected Decision From CT Supreme Court Changes Standard of Proof for Residency for Estate Appeals

In an advance opinion released today The Connecticut Supreme Court “changed the rules” on how disputes regarding domicile for estate tax disputes will be handled in the future, Daniels v. Commissioner of Revenue Services (SC 21150).  FLB Law’s Trust and Estate practice is actively communicating with its high-net-worth clients who reside in multiple jurisdictions to explain how the Connecticut Supreme Court's decision lowers the burden of proof in estate tax domicile disputes from "clear and convincing evidence" to a more relaxed "preponderance of the evidence" standard, impacting future residency and estate tax controversies. The decision highlights the importance of thoughtful domicile planning and maintaining consistent actions that support a taxpayer's intended state of residence, particularly for individuals with homes and significant ties in multiple states.

For more information or questions please contact Stephen Fogerty(fogerty@flb.law) or Lesile Grodd (grodd@flb.law).