Every year, Colorado witnesses one of nature’s great migrations. Geese fly south. Elk descend from the mountains. Texans arrive and attempt, without snow tires, to drive through snow.

And now, apparently, corporations may flee Colorado in search of more favorable tax treatment if you believe what the opponents of Amendment 87, which cuts taxes for individuals and corporations with less than $500,000 in taxable income and raises them on the rest, are saying.

Which raises an important question:

Flee to where?

Because America’s large corporations have been preparing for this moment for approximately 40 years.

They’re already incorporated in Delaware. Their headquarters are in Texas. Their call center is in India. Their intellectual property is owned by something called Global Holdings Luxembourg B.V., and their profits are visiting Ireland for reasons their accountant assures us are cultural.

There’s not much corporation left to migrate.

The mental image seems to be that Walmart hears Colorado raised its corporate tax rate and immediately holds an emergency meeting.

CEO: Bad news. Colorado raised taxes.

CFO: Dear God.

CEO: Pack everything.

CFO: Everything?

CEO: Headquarters to Texas. Incorporation papers to Delaware. Accounting to Dublin. Call center to Bangalore.

CFO: Sir, we already did all of those things.

CEO: Then why are we still paying Colorado taxes?

CFO: Coloradans keep buying our stuff.

CEO: Can we move them?

And that’s the part of corporate taxation that gets lost in these debates.

Colorado uses something called single-sales-factor apportionment, which sounds like a medical condition you develop from reading too many spreadsheets. (DOCTOR: I’m afraid it’s single-sales-factor apportionment. I’m prescribing two weeks without Excel and absolutely no VLOOKUP after 8 p.m.)

But the idea is surprisingly simple.

If a multistate corporation makes money selling things all over America, Colorado generally taxes the portion of its income associated with sales to Colorado customers.

Suppose Acme Corporation earns $1 billion nationwide and 2% of its sales are in Colorado. Colorado doesn’t particularly care that Acme’s CEO lives in Dallas, its legal address is a filing cabinet in Wilmington and its corporate strategy retreats are held somewhere with a suspicious number of palm trees.

Colorado essentially says, “Nice organizational chart. You sold 2% of your stuff here.”

Walmart isn’t going to close every Colorado store, abandon billions in Colorado sales and station an employee at the Wyoming border yelling, “COME GET YOUR TOILET PAPER IN CHEYENNE!” because Colorado changed its corporate income tax rate.

And here’s another detail missing from the panic over Amendment 87: most corporations aren’t even the corporations we’re talking about.

Of roughly 68,000 corporations filing in Colorado, only about 13,000 report more than $500,000 in taxable income. Under Amendment 87, corporations below that threshold would actually receive a tax cut. And according to an analysis by the Institute on Taxation and Economic Policy cited by Protect Colorado’s Future, 94% of the additional corporate income tax revenue would come from businesses based outside Colorado. Overall, Amendment 87 is projected to raise approximately $2 billion annually for schools, health care and child care.

So when someone says, “Amendment 87 raises taxes on Colorado corporations,” don’t picture Ed closing the register at his family hardware store in Pueblo. The corporations actually paying the higher rate look more like OmniCorp International Holdings, Global Consumer Products & Nacho Solutions LLC.

And here’s another weird part: U.S. corporate profits are at record highs while Colorado’s corporate income tax collections fell 40.9% in fiscal year 2025-26. That’s largely because federal tax breaks in the “One Big Beautiful Bill Act” flow through to Colorado’s tax base, creating new deductions for corporations and contributing to unusually large tax refunds. Corporations are making more money while Colorado collects dramatically less tax on it.

The academic literature generally backs up the underlying logic. Corporate location decisions respond to taxes at the margins, but research on corporate headquarters relocations and state tax policies finds an important distinction: The relationship between corporate tax rates and headquarters relocations is weaker in states that place little or no weight on payroll and property in their tax formulas. Raising a tax tied to where your customers are is much harder for a corporation to escape merely by moving its headquarters.

Taxes can affect corporate decisions at the margins, and economists debate the size of those effects. But when it comes to the claim that higher rates will send corporations fleeing Colorado en masse and actually cause corporate tax revenue to fall, that debate largely comes down to how you interpret a highly technical phrase that appears repeatedly in the economic literature: “Yeah, Probably Not.”

Actually, economists probably have a much longer term involving the words elasticity, incidence and spatial equilibrium. But that’s why nobody invites us anywhere.

The larger point is that corporations aren’t people packing a U-Haul.

They can move executives. They can move factories. They can move paperwork.

But if they want to keep selling groceries, televisions and 48-packs of toilet paper to six million Coloradans, there’s one thing that’s considerably harder to move: Colorado.

(And if you’re going to try, Texans, please bring snow tires.)

Vote yes on Amendment 87.