Tax
Oct. 15, 2026
California's billionaire tax puts residency under the microscope
California's proposed billionaire tax could trigger legal disputes over retroactivity, residency and asset valuations, while increasing scrutiny of taxpayers who move out of state and raising broader concerns about future wealth taxes.
Robert W. Wood
Managing Partner
Wood LLP
333 Sacramento St
San Francisco , California 94111-3601
Phone: (415) 834-0113
Fax: (415) 789-4540
Email: wood@WoodLLP.com
Univ of Chicago Law School
Wood is a tax lawyer at Wood LLP, and often advises lawyers and litigants about tax issues.
For Californians considering a move out of state, the proposed billionaire tax on November's ballot is a reminder that where you live, when you leave and how well you document your change of domicile can have lasting tax consequences. California's Franchise Tax Board has long scrutinized moves to other states, particularly those occurring shortly before major income events. Proposition 40 could add another layer of controversy over residency, timing and the state's authority to...
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