Moving to Florida to Avoid Estate Tax — Is It Worth It? Domicile Requirements?

Sorry for the wall of text. My parents (both late 60s) split time between a co-op in Manhattan and a condo in Naples. Combined estate is ~$12M. If they die as New York domiciliaries, the NY estate tax on a $12M estate is roughly $1.1M (the cliff kicks in because they're over 105% of the exemption).

If they establish Florida domicile: $0 state estate tax. Zero.

The savings seem obvious but I've heard horror stories about New York challenging domicile changes. Does anyone have experience with this? What's the checklist to make it bulletproof?

Rhode Island is generally not aggressive about domicile audits the way NY and CT are. The Rhode Island estate tax guide covers the state-specific rates. With $130K at stake, the move to Florida would pay for itself many times over. Just make sure you follow the full domicile checklist and keep records of your days spent in each state fr fr.