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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.

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California's billionaire tax puts residency under the microscope
Shutterstock

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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