The Internal Revenue Service has blessed similar arrangements that California has used to raise money for college scholarships, and that several states use to preserve land from development or generate money for private school vouchers. But it’s one thing to offer a tax break to try to support a public project or service; it’s another to do it solely to cut Californians’ federal tax bills. Passing the De León bill would be the state’s version of setting up a shell company in the Cayman Islands in order to shelter Californians’ income.

The basic premise of the still-evolving state plan, vaguely unveiled during Cuomo’s State of the State speech last week, is to sharply reduce the state’s reliance on income taxes that employees pay by starting a new, statewide payroll tax that employers would pay.

It’s a tricky initiative, starting with the fact that personal income taxes — $48 billion — account for 64 percent of the total taxes and fees Albany collects each year.