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California’s Billionaire Tax Act: The Challenge of Changing Residency On Short Notice, For Billionaires and Non-Billionaires Alike

What’s Happening Rarely has a potential change in tax law affecting so few taxpayers attracted as much attention as California’s 2026 Billionaire Tax Act. By definition, the proposed legislation, which takes the form of a ballot initiative subject to a popular vote, only applies to the rarified demographic of taxpayers…

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Moving to California After a Liquidity Event: A New FTB Case Highlights All the Mistakes Nonresidents Can Make

The Case A recent case from California’s Office of Tax Appeals brings some clarity to how strictly  California dates a change of residency for income tax purposes when a nonresident claims to have moved to California shortly after a liquidity event. The case, Appeal of Housman, OTA Case No. 18010200…

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California’s 4600 Notice “Request For Tax Return” – The Definitive Guide for Nonresidents

  The Issue ​Nonresidents who own vacation homes, business interests, financial accounts, or have other significant contacts in California can receive a notice from the Franchise Tax Board, California’s tax enforcement agency, demanding they file a tax return or explain why they aren’t required to. The official notice number is…

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Guidelines for Determining California Residency: A Primer for Serious Snowbirds

  Seasonal Visitors to California and Residency Anxiety Out-of-state visitors who own vacation homes in California or otherwise spend significant time here on a seasonal basis (traditionally known as “snowbirds” because the season is inevitably winter) are often anxious about their residency status. There’s good reason to be. California rules…

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