For the operating-cash and stochastic-buffer tiers, the largest single after-tax move is choosing a vehicle whose interest is exempt from state income tax. Direct obligations of the United States — T-bills, T-notes, T-bonds, STRIPS — are state-tax-exempt under 31 U.S.C. § 3124. The exemption is invisible if you live in Texas or Florida and decisive if you live in California, New York, or any other high-state-tax jurisdiction.
Treasury-only vs. Government MMF Two money-market funds with similar nominal yield can have very different after-tax yields depending on what sits inside them:
Hold direct US Treasury obligations almost exclusively. Interest passes through as state-tax-exempt federal-obligation income, reported on Form 1099-DIV with a supplemental percentage you use on your state return.
Hold a mix of Treasuries, agency debt, and repurchase agreements. Repo income, despite being collateralized by Treasuries, is not state-tax-exempt. The state-exempt percentage on a typical government MMF commonly runs in the 20–55% range, year to year.
For California, Connecticut, and New York residents there is an additional cliff: state law permits the federal-obligation pass-through only if at least 50% of the fund’s assets sit in qualifying US obligations at the relevant measurement dates (California R&TC § 17145 is the operative rule). SPAXX and similar government MMFs commonly drift below that 50% line because of their repo allocation, and when they do, none of the dividend is state-tax-exempt in those states for that year. A 40% state-exempt fund nationally pays zero state exemption in California. This is the kind of detail your tax preparer fills in for you silently while you wonder why the after-tax yield came out so low.
Worked example, California A California resident in the 37% federal bracket and the 14.3% state bracket (13.3% top + 1% BHST), well over the NIIT threshold (
NIIT = 0.038
Government MMF at 4.5% nominal, 0% state-exempt (failed cliff):
after-tax = 0.045
Treasury-only MMF at 4.3% nominal, 100% state-exempt:
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