The wealthy folks who are already carefully tracking their days in NYS will continue doing that even if their taxes stay the same. And they will continue doing that even if NYC taxes fall dramatically. They will continue doing it unless NYC's taxes fall to Sioux Falls, SD levels, which is simply not realistic. So this group of people can be entirely discounted in any talk of income tax policy. They are not going to change their residency under any realistic income tax model.

The wealthy folks who are spending 183+ days per year in NYC now are going to keep doing that even if their taxes go up a few percent. This group of people wants to spend 183+ days per year in NYC and can afford to do so. These folks also aren't going to change their residency under any realistic income tax model.

The previous commenter suggested that there is a group of wealthy folks who will suddenly "discover" the 183-day rule if taxes go up a few percent. The idea that there is any sizable number of wealthy folks whose accountants and lawyers haven't told them about the 183-day rule years ago is ludicrous.