California’s Proposed Billionaire Wealth Tax and the Question of State Residency
Can billionaires simply switch their state residency and avoid the tax? Most press accounts, as well as the Hoover study, treat the residency question as one that answers itself via self-certified acts: a billionaire announces a new home state, purchases property there, or moves a business entity, and the desired legal outcome automatically materializes. This framing radically oversimplifies the complex inquiry required to determine whether an individual has ceased to be a California resident as a matter of law.