THE MASSACHUSETTS MILLIONAIRES SURTAX AND THE CHALLENGE OF RESTORING JOB GROWTH
Massachusetts’ recent reversal in employment performance represents a striking departure from its decade-long record of labor-market dynamism. After more than ten years of above-median private-sector job creation, the Commonwealth fell to the bottom of national rankings in 2023–2024, recording a 0.6 percent decline in private employment and ranking fiftieth among the states (Massachusetts Taxpayers Foundation 2025). The coincidence between this inflection and the passage of the four percent “Fair Share” surtax on income above one million dollars, approved by voters in November 2022 and effective for the 2023 tax year, suggests that the new levy has altered incentives in ways detrimental to growth.
The Surtax and Behavioral Response
The surtax reduces the after-tax return to entrepreneurship, partnership income, and capital gains, which together constitute the key channels through which high-income households create new enterprises and employment. Expectations of higher taxation influence decisions even before collection begins; the progression of the surtax from ballot qualification in mid-2022 to final approval later that year provided a clear signal to business owners and investors.
Recent judicial decisions reinforce these behavioral effects. In Welch v. Commissioner (2025), the Massachusetts Appeals Court upheld the state’s right to tax nonresidents on gains derived from in-state business activity, even after relocation. This expansive sourcing rule extends potential tax exposure beyond the point of exit and strengthens the incentive for high-income founders to plan relocations and investment decisions outside Massachusetts. Taken together, these developments plausibly explain the sharp deterioration in relative job growth that no national or long-standing local factor can replicate in timing or magnitude.
Other structural disadvantages, including high energy prices, housing scarcity, and persistent transit deficiencies, have burdened Massachusetts firms for years without preventing robust employment growth (Massachusetts Taxpayers Foundation 2019; U.S. Energy Information Administration 2024). Their endurance during the earlier boom suggests that the 2022–2023 reversal required a new, state-specific shock. The surtax uniquely fits that description. Broader macroeconomic and sectoral forces have also weighed on hiring, but these trends are national and cannot account for Massachusetts’ singular decline in job creation relative to its peers.
Policy Options for Reinvigorating Job Creation
How do we get back on the growth track? Outright repeal of the surtax would most directly restore competitiveness. However, its constitutional status and continuing popular support make repeal politically difficult. The state must therefore offset the surtax’s drag through measures that reduce costs and uncertainty without creating new administrative burdens.
1. Simplify and Accelerate Permitting. Enforceable “shot-clocks” for state and local approvals, with automatic approval if deadlines lapse, would provide the predictability investors require. Massachusetts already operates an expedited local permitting framework under Chapter 43D of the General Laws, which could be extended to a broader range of projects (Massachusetts Department of Housing and Community Development 2023). A complementary “permit-by-rule” regime for low-impact developments and an expansion of the pre-cleared “site-readiness” program would further reduce development timelines without additional bureaucracy (MassDevelopment 2024).
2. Modernize the Tax Treatment of Investment Interest Expense. Massachusetts currently disallows such deductions for individual taxpayers (Massachusetts Department of Revenue Directive 86-8). Clearly establishing deductibility of investment-interest expense in conformity with federal law would lower the cost of capital for in-state reinvestment. This reform would also likely reduce the outmigration of wealthy families.
3. Rationalize Occupational Licensing. A statute providing universal recognition of out-of-state occupational licenses would enable skilled migrants to work immediately, increasing labor-market fluidity without creating new boards or agencies. As of 2024, more than two dozen states have adopted such frameworks (Cicero Institute 2023).
4. Address Foundational Cost Pressures. Although high energy prices and infrastructure bottlenecks are long-term challenges, expanding pipeline and transmission capacity remains essential for stabilizing industrial and commercial electricity costs. The 2024 Massachusetts energy-siting reform law provides a foundation for more predictable infrastructure permitting through single-agency coordination and binding timelines (Massachusetts Executive Office of Energy and Environmental Affairs 2024).
5. Institutionalize Simplicity. Adopting a regulatory-budget or sunset rule that caps the aggregate number of regulations or paperwork hours, or that requires one regulation to be repealed for each new one enacted, would create a durable discipline of administrative simplicity (Cicero Institute 2023). Enhancing the existing Community One-Stop portal for economic-development permits to eliminate redundant data entry and provide real-time status tracking would further streamline interactions between businesses and government (Massachusetts Executive Office of Economic Development 2024).
Conclusion
The post-2022 slowdown in Massachusetts’ job creation most likely stems from the behavioral and expectation effects of the millionaires surtax rather than from the enduring structural costs that coexisted with growth during the previous decade. How can we restart the stalled growth and thereby secure the fiscal future of the Commonwealth? Because repeal of the surtax is politically constrained, the Commonwealth’s best path forward is a set of focused, bureaucracy-light reforms: faster permitting, modernized tax conformity, licensing mobility, targeted infrastructure streamlining, and regulatory simplification. Collectively, these measures would reaffirm Massachusetts’ reputation as a state that rewards innovation and enterprise, thereby restoring the conditions for sustainable employment growth even within the existing fiscal framework.
The Long-Term Economic Risks of the Massachusetts Millionaires Surtax
The Massachusetts Fair Share Amendment, popularly known as the “millionaires surtax”, imposed an additional 4 percent tax on annual personal income above one million dollars beginning in 2023. Proponents framed it as a progressive and sustainable revenue source dedicated to education and transportation.
In the short run, receipts have indeed exceeded expectations, generating over two billion dollars annually. However, early fiscal success masks the deeper structural and behavioral forces that threaten Massachusetts’ long-term economic vitality. The surtax changes the incentive structure for high-income households, closely held businesses, and entrepreneurs, gradually undermining the very tax base it was designed to tap.
In the near term, the surtax has primarily manifested through a pronounced deceleration in hiring and investment. Massachusetts has shifted from being a top-quartile performer in job creation during the 2010s to ranking last in the nation for private-sector employment growth in 2023–2024. The timing of this reversal closely aligns with the passage and implementation of the surtax. Businesses dependent on high-skill human capital and founder-led investment have become less inclined to expand locally, and many have redirected incremental hiring toward more tax-competitive jurisdictions. This initial stagnation represents the “first-order” impact—an early signal of capital reallocation rather than immediate firm closures or relocations.
The deeper effects are likely to unfold over a longer horizon. A substantial portion of the households subject to the surtax are not transient speculators but long-established families with complex ties to Massachusetts—children in local schools, businesses embedded in regional networks, and real estate holdings. Rather than exiting abruptly, these households are engaged in multi-year transition planning. Many are deferring relocation until children complete secondary education or until the sale of their Massachusetts-based business can be executed efficiently. Because of these demographic and financial frictions, the immediate revenue response to the surtax overstates its durability.
Massachusetts tax law further complicates mobility through what effectively functions as an “exit tax.” The state asserts taxing authority over non-residents’ gains from the sale of Massachusetts-based businesses if those gains are linked to in-state labor or operations. Courts have recently upheld this expansive sourcing doctrine, confirming that even after a taxpayer has changed residency, the Commonwealth may still claim tax on the appreciation of an enterprise built within its borders. This enforcement posture discourages early relocation but does not alter the ultimate calculus—it merely delays it. High-net-worth individuals are incentivized to remain nominal residents through the liquidity event, harvest offsetting capital losses through sophisticated investment accounts, and then emigrate permanently once the tax-efficient window closes.
The fiscal illusion created by this lag is substantial. In the early years of implementation, surtax revenues appear robust, as high-income residents remain on the tax rolls while completing transactions. Yet these inflows are effectively front-loaded: they represent one-time realizations of embedded gains rather than ongoing income streams. As the deferred migration unfolds, Massachusetts faces the erosion not only of surtax proceeds but also of its regular 5 percent income tax base. Each departing household removes a disproportionate share of total personal income, investment capital, and philanthropic activity, compounding the long-run contraction of the tax base.
From a macroeconomic standpoint, this dynamic threatens the state’s competitive equilibrium. Massachusetts’ growth model has long depended on its concentration of intellectual and financial capital. This capital is founders, partners, and high-skilled professionals whose risk-taking supports a dense ecosystem of innovation, education, and services. By materially reducing the after-tax return on those actors’ marginal decisions, the surtax discourages in-state reinvestment precisely among the individuals most capable of generating new enterprises and employment. Over time, the outflow of entrepreneurial talent and wealth will depress aggregate investment, diminish private-sector dynamism, and constrain future revenue elasticity.
The long-term risk is therefore structural rather than cyclical. In the coming decade, Massachusetts could experience a gradual hollowing of its high-income and high-growth cohort while fixed public expenditures expand on the assumption of stable surtax receipts. When migration and demography finally reconcile with fiscal expectations, the state may confront widening deficits, reduced capital formation, and declining competitiveness relative to peer innovation states. The pattern mirrors what empirical literature on state-level progressive surtaxes has observed elsewhere: initial revenue booms followed by tax-base erosion and slower economic growth once mobility and behavioral responses fully materialize.
In summary, the Massachusetts millionaires surtax has produced a short-term illusion of fiscal abundance but at the cost of weakening the long-run foundations of economic growth. The delayed migration and business-sale timing strategies of affluent taxpayers mean that the eventual revenue loss will emerge gradually over the next five to ten years. When it does, the Commonwealth will face the combined challenge of shrinking high-income residency, diminished private-sector expansion, and rigid spending commitments built on transient windfalls. The policy’s ultimate legacy may thus be not sustainable progressivity, but a self-inflicted erosion of the tax base and the economic dynamism that once made Massachusetts a national leader.