California business owners: How to leave California without starting over [CA Wealth Tax: Prop 40]
Attorney and CPA Chad D. Cummings notes that California’s proposed billionaire tax is producing the exits its supporters were warned about. Politico reports that Sergey Brin began cutting ties with the state late last year, following Larry Page. Peter Thiel moved to Miami and cited the tax environment. Don Hankey moved to Nevada and said he no longer felt wanted. Leading California tax attorneys told Politico they have quietly moved at least another half-dozen billionaire clients. If voters approve Proposition 40, the state expects about $100 billion, roughly one-third of the annual budget. Taxpayers have billions of reasons to establish residency elsewhere. The Franchise Tax Board has about $100 billion of reasons to argue they never left. California does not decide residency by a driver’s license. Inventor Gilbert Hyatt sold his California home, rented in Nevada, opened a Nevada bank account, and re-registered his vehicles before a roughly $150 million patent windfall. The Franchise Tax Board still went through his trash, read his mail, and contacted his rabbi. The fight lasted about a quarter-century, reached the U.S. Supreme Court three times, and left Hyatt paying about $11 million. Courts look for the center of life: purchases, doctors, family, property, and where the business actually sits. Residency attorney Christopher Manes put it plainly: you can buy the Palace of Versailles, but you have to actually leave. Meanwhile, state like Florida and Texas impose no personal income tax and no wealth tax. Redomestication can move an existing company without dissolving it. Changing the mailing address does not end the analysis. Learn how to move a company out of California: https://www.cummings.law/redomestication/move-business-out-of-california/
8 Oct 2026
How to transfer your company out of New York without starting over [step-by-step]
Attorney and CPA Chad D. Cummings notes that New York City’s second-home tax has already failed a basic test: identifying who owes it. The Telegraph reports that a judge ordered Mayor Zohran Mamdani’s administration to start again after thousands of primary residences were wrongly flagged for the surcharge. The mayor’s office admitted notices went out in error. A known tax can be modeled. A misclassification cannot. The owner of a primary residence still has to hire counsel, assemble records, and prove the city’s file is wrong, and that cost does not disappear when the assessment is later withdrawn. New York is already arguing over whether wealthy residents and firms will keep absorbing new levies. A court order to restart the rollout is an execution problem, and execution problems belong in the jurisdiction’s risk profile. Redomestication can move an existing company without dissolving it. The expensive tax is not always the one with the highest rate. Sometimes it is the one you were never supposed to owe. Learn about how to move your company out of New York without starting over: https://www.cummings.law/redomestication/move-business-out-of-new-york/
6 Oct 2026
Illinois crypto tax: how to redomicile your company out of Illinois [step-by-step]
Attorney and CPA Chad D. Cummings notes that Illinois will be the first state with a dedicated tax on digital asset transactions. Beginning January 1, 2027, the rate is 0.2 percent of the value of digital assets exchanged, transferred, or stored for Illinois customers. The tax reaches brokers with an Illinois place of business or at least $100,000 of Illinois gross receipts in a 12-month period. Registration is broader than collection. Jones Day reports that even one covered transaction with an Illinois customer requires a certificate from the Department of Revenue, and operating without one can be a Class 3 felony. Storage is taxable, so exchanges, custodial wallets, and cold-storage services can fall in. Receipts are presumed Illinois unless the broker proves otherwise, and implementing rules were not yet out. Possible Commerce Clause and Internet Tax Freedom Act challenges do not pause the compliance burden. A digital company can serve the country from almost anywhere. It cannot assume every state imposes the same cost. Florida and Texas impose no personal income tax. Redomestication can move an existing company without dissolving it. Illinois just created a regime no other state has, and firms now have to price it. Learn about how to move your company out of Illinois and keep your EIN: https://www.cummings.law/redomestication/move-business-out-of-illinois/
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