This is why so many corporations are moving their headquarters to Ireland or other off shore locations. The tax implications for people who can afford to hire $500/hour lawyers and tax accounts are just too much to ignore
This is along the same lines as John Kerry keeping his new sailing yacht in RI and Mass coming after him for the taxes they thought he owned them. They try this with everybody.
My father in law about ten years back used to keep his sailboat in Boston/Charlestown harbor in the winter. This was NOT a big boat. It was a 30’. The state of Mass tried to say he was a part time resident because he kept his boat there 6 months a year.
He promised to pay those taxes, leave him be.</sarcasm>