
Hosted by Cummings & Cummings Law · EN

Attorney and CPA Chad D. Cummings discusses the upcoming California wealth tax ballot measure in this presentation as reported by Stephen Foley of the Financial Times. Proposition 40, which would impose a five percent tax on the net worth of California billionaires, has qualified for the November 3, 2026 general election and is shaping up as one of the most expensive and closely watched referendum battles in the state’s history. Backers argue it will raise $100 billion to replace lost federal healthcare funding, while opponents, including a broad coalition of billionaires, unions, and Governor Newsom, warn of capital flight, economic damage, and the likelihood that the tax will not remain limited to billionaires. This presentation examines the proposal’s details, the early exodus of high-net-worth individuals, the spoiler measures on the ballot, and the strategic implications for California business owners. Redomestication offers a proven path to transfer a company out of California without dissolution and without federal income tax consequences when performed correctly. If you own a business in California, the stakes of this vote are significant. Learn more: https://www.cummings.law/redomestication/move-business-out-of-california/

Attorney and CPA Chad D. Cummings discusses the aggressive residency audits by the California Franchise Tax Board in this presentation. Following the qualification of the California Billionaire Tax Act for the November 2026 ballot, the FTB has launched some of the most intrusive audits in its history, demanding GPS records, transaction data, and other evidence from departing high-net-worth individuals. This enforcement posture applies not only to individuals but to every business entity still domiciled in California, regardless of size. If your LLC or corporation remains formed in California, the FTB retains jurisdiction even if you personally relocated. This presentation explains how redomestication allows business owners to transfer their company out of California without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business still domiciled in California, the current audit activity and budget pressures make the timing urgent. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses the impact of major liquidity events on California business owners and the accelerating exodus to Florida in this presentation. SpaceX’s June 12, 2026 IPO at a valuation exceeding two trillion dollars created approximately 4,400 new millionaires in California, where the top marginal income tax rate is 13.3 percent. For an employee receiving ten million dollars in equity, that means a California tax bill of $1.33 million compared to zero in Florida. Similar events at companies like OpenAI are generating another wave of newly liquid California residents who have one opportunity to establish residency in a no-income-tax state before their gains are taxed. Brokers in South Florida report a surge of California area codes, and the pattern is clear: the people leaving are not retiring. They are founding companies, hiring employees, and deploying capital. This presentation explains how redomestication allows business owners to transfer their company’s legal domicile out of California without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in California, the math and the timing make the decision urgent. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings analyzes recent U.S. GDP growth data and the migration patterns driving it in this presentation. In 2025, the national economy grew 2.1 percent in real terms, with every state expanding. Florida led at 3.1 percent, Texas at 2.5 percent, and the Sun Belt outperformed the national average while high-tax states like California and New York showed slower underlying momentum when viewed alongside continued population loss. IRS migration data confirm that the states gaining residents and growing above the national average are those with no income tax and lower costs of doing business. This presentation shows how redomestication allows business owners to transfer their company’s legal domicile to Florida or Texas without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in a state losing population while relying on concentrated sector performance, the formula is clear. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses the accelerating trend of companies redomesticating from Delaware to Texas in this presentation. In June 2024, Tesla and SpaceX led the way. By June 2026, the movement has expanded significantly, with eight additional companies, including Dell Technologies, voting to redomesticate in a single month, representing a combined market value of approximately $290 billion. Since June 2024, more than 25 companies with over four trillion dollars in aggregate market value have committed to the move. This presentation examines the governance and tax advantages of Texas, the statutory conversion process used by these large corporations, and how the same redomestication mechanism is available to small and mid-sized businesses. Redomestication transfers the entity to a new state without dissolution and without federal income tax consequences when performed correctly, preserving the FEIN, contracts, credit history, and bank accounts. If you own a business still domiciled in Delaware or another high-tax state, the pattern is clear. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings reviews the California wealth tax ballot measure and the recent cease-and-desist letters sent by its authors to a critic. We discuss how the proposal, marketed as a one-time tax on billionaires, has already driven departures of significant wealth and income tax revenue, and how the authors have responded to criticism with legal threats rather than substantive debate. We also cover the broader implications for California business owners, including the risk of expanding wealth taxes and the importance of redomestication as a strategic tool to protect your company. Redomestication transfers your entity’s domicile to another state without dissolution and without federal income tax consequences when performed correctly, preserving your FEIN, contracts, credit history, and bank accounts. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses the qualified California Billionaire Tax Act ballot measure in this presentation. The measure, which would impose a five percent wealth tax on billionaires’ assets, has officially qualified for the November 3, 2026 general election despite opposition from Governor Newsom, Planned Parenthood Affiliates of California, the California Teachers Association, and others. Even before a single vote, the proposal has already driven significant departures, with billionaires such as Mark Zuckerberg, Larry Page, Sergey Brin, Peter Thiel, and David Sacks relocating out of state and costing California substantial ongoing income tax revenue at the 13.3 percent top marginal rate. This presentation explains how redomestication, paired with a change of personal residency and reduction of business operations in California, allows business owners to protect their companies from these expanding tax risks. The process transfers the entity’s domicile without dissolution and without federal income tax consequences when done properly. If you own a business in California, the pattern is clear. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings analyzes the lessons from Europe and the risks of California’s proposed wealth tax in this presentation. Of the twelve industrialized countries that imposed wealth taxes in 1990, nine repealed them by 2025 because the taxes proved difficult to administer, drove wealthy residents away, and generated far less revenue than projected. France lost an estimated 200 billion euros over two decades and repealed its wealth tax in 2018. Stanford economists Joshua Rauh and Benjamin Jaros applied that experience to California’s ballot measure and estimated it would raise only about $40 billion—not the $100 billion claimed—with 30 percent of the targeted billionaire wealth base already having left before the residency deadline. The federal proposal has already dropped the threshold from one billion to fifty million dollars and includes a 40 percent exit tax. This presentation explains how redomestication, paired with a change of personal residency and reduction of business operations in California, allows business owners to move their companies out of California. The process transfers the entity’s domicile without dissolution and without federal income tax consequences when done properly. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings discusses the rapid expansion of wealth tax proposals targeting California business owners in this presentation. What began as a ballot measure marketed as a five percent tax on billionaires has already broadened, with federal proposals now aiming at net worth above fifty million dollars and a 40 percent exit tax for those who leave. California’s aggressive residency audits through the Franchise Tax Board, combined with the pattern seen in other jurisdictions where thresholds creep lower over time, make the risk immediate. Florida and Texas impose no state personal income tax and no wealth tax. This presentation explains how redomestication allows business owners to transfer their company’s legal domicile to a new state without dissolving the entity, without creating a new company, and on a completely tax-free basis while preserving the same FEIN, contracts, credit history, and bank accounts. If you own a business in California, the direction of these proposals makes clear why now is the time to act. Learn more: https://www.cummings.law/redomestication/

Attorney and CPA Chad D. Cummings explains the strategic benefits of timely filing an Section 83(b) election in this presentation. By filing within 30 days of receiving property subject to a substantial risk of forfeiture, you lock in ordinary income recognition at the grant-date fair market value rather than at each vesting date, convert future appreciation into capital gain, start the capital gains holding period immediately, eliminate uncertainty around future tax rates and vesting events, and simplify the treatment of LLC or partnership interests. These advantages can deliver substantial tax savings when the property’s value at grant is low relative to its expected future value, but the election is irrevocable, carries risk if the property is forfeited, and must be filed correctly with no extensions. This presentation covers when the election makes sense, the mechanics, common pitfalls, and why professional guidance is essential. Learn more: https://www.cummings.law/onboard/83b/index.html