No. Simply storing items in another state generally doesn't impact your Florida residency if you've clearly demonstrated intent and taken proper steps to establish domicile.
When moving to Florida and establishing residency (domicile), some individuals worry about whether storing personal belongings in another state could affect their residency status or tax situation.
Here's a simplified breakdown with references to relevant legal cases:
What is Florida domicile?
To become a Florida resident legally, you must:
1. Intend to live in Florida permanently.
2. Take actions showing this intent.
Florida considers various factors, including:
Filing a declaration of domicile
Obtaining a Florida driver's license
Registering your vehicle in Florida
Registering to vote in Florida
Working in Florida
Using a Florida address for taxes
Having bank accounts in Florida
Paying utility bills in Florida
Relevant cases include:
- Bloomfield v. St. Petersburg Beach, which emphasizes intent and concrete actions to establish domicile.
- Wade v. Wade, which discusses weighing various acts and declarations to determine domicile.
Does storage in another state matter?
Florida courts do not specifically state that storing items in another state prevents establishing residency. They instead look at multiple factors collectively.
However, other states have sometimes viewed out-of-state storage negatively. For example:
In Mauer v. Comm’r of Revenue, Minnesota courts viewed maintaining insured property in another state as evidence against establishing residency in a new state.
Michigan considers the location of significant personal belongings but does not consider storage alone determinative.
Florida's approach
Florida uses a holistic approach, focusing on overall intention and concrete actions. Storing items in another state is typically considered a practical choice rather than evidence of intent to maintain residency elsewhere.
Recommendations to ensure Florida residency
Clearly establish your Florida residency by:
- Filing a declaration of domicile in Florida.
- Obtaining a Florida driver's license and registering your vehicle.
- Registering to vote in Florida.
- Filing federal income taxes using your Florida address.
- Establishing primary banking relationships in Florida.