But what about place of earning versus realization? Anyone could just defer conpensation to the extent they can, relocate to FL/TX and avoid paying state taxes
- PT21
You're describing exactly what people with high earnings do. Most people can't defer their comp (they need it now) and don't have the means to just move whenever they want.
This is really only a conversation for those that are already maxing their retirement tax deferment strategies. It doesn't make sense for most people.
What you cannot do (and you will go to jail for) is say you earned 0$ in a particular state, defer your comp to a future date, move, and then receive it in an advantageous tax environment. If you earn a reasonable salary for the work you do at the time, the deferred comp won't be an issue to the relevant taxing authority.
There literally is nothing stopping anyone from being compensated in this way other than it's complicated to setup contractually (expensive with lawyers and tax professionals) and most people are not as important as Jarvis or Ohtani to their companies.