New Connecticut Estate Tax Ruling

If you (or a family member) maintain homes or significant ties in more than one state, a recent Connecticut Supreme Court decision is a useful reminder that domicile—your “true, fixed, and permanent home”—can materially affect Connecticut estate tax exposure.
The decision in plain English (Daniels v. Commissioner of Revenue Services / Estate of Jack Anderson)In Daniels v. Commissioner of Revenue Services (Docket No. 21150, released June 16, 2026), the Connecticut Supreme Court addressed a domicile dispute involving the Estate of Jack Anderson, who divided time among homes in Connecticut, Arizona, and Florida. Connecticut’s Department of Revenue Services treated him as a Connecticut resident for estate tax purposes, and the executor challenged that conclusion.
The Court held that the executor must prove the decedent was not domiciled in Connecticut by a preponderance of the evidence (i.e., “more likely than not”)—not by the higher “clear and convincing evidence” standard that the lower court used. The case was reversed and remanded because the lower court applied the wrong standard. Connecticut estate tax guidance now reflects this rule.
The practical effect of this decision is to lower the burden of proof for an executor who claims a decedent was not domiciled in Connecticut. But there still is a burden of proof.
Why it matters if you have homes or ties in multiple statesConnecticut taxes resident estates and nonresident estates differently. If Connecticut treats you as domiciled in Connecticut at death, Connecticut may tax the estate more broadly, including intangible property included in the federal gross estate, regardless of where that property is located. By contrast, if you are a nonresident, Connecticut’s estate tax applies to only Connecticut real property and Connecticut-situs tangible personal property.
Practical, action-oriented steps to help document domicileIf you intend to establish or maintain domicile outside Connecticut (or you want to reduce ambiguity), consider whether your records and actions consistently support that position:

• Track time spent in each state: keep calendars and travel records.
• Align “legal” connections: driver’s license, voter registration, vehicle registration, and primary address should match the intended domicile.
• Be consistent on tax filings and forms: avoid contradictory addresses or residency positions across returns and related documents.
• Review estate planning documents: ensure wills, trusts, powers of attorney, and health care directives reflect the intended domicile.
• Update financial/personal ties: mailing addresses for banks/brokerage, insurance, physicians, memberships, and other recurring relationships.

If an estate will claim Connecticut nonresident status, Connecticut DRS states that the estate must file Form C-3 UGE, State of Connecticut Domicile Declaration, with DRS or the Probate Court depending on jurisdiction. That filing should be consistent with the underlying facts and records.
Next step: let’s review your plan (and your documentation)If you have multiple residences, spend significant time outside Connecticut, or are contemplating a move, I am happy to help you evaluate domicile risk and make sure your estate plan and supporting documentation match your intended home state.