Articles Posted in California residency audit

Moving Out of California Taxes: How to Avoid an FTB Audit
Kugelman Law

When it comes to moving out of California, taxes are the part most people underestimate. Leaving the state does not automatically end your California tax exposure, and high earners who relocate are exactly the people the Franchise Tax Board (FTB) tends to examine. A clean departure is one you can prove: a genuine change of…

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How to Fight a California Residency Audit
Kugelman Law

To fight a California residency audit, you have to do more than say you moved. The Franchise Tax Board (FTB) starts from the assumption that you never really left, and it will test that assumption against your bank records, travel history, and daily location data. Winning means responding carefully, documenting where your life actually centers,…

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California Billionaire Tax: What Proposition 40 Means for You
Kugelman Law

The California billionaire tax, Proposition 40 on the November 3, 2026 ballot, proposes a one-time 5% tax on the net worth of state residents worth $1 billion or more. As written, it would reach only a few hundred people. Its real significance for the broader high-net-worth community is what it signals: California is sharpening its…

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California QSBS: Why the State Won’t Match the Federal Tax Break
Kugelman Law

If you are a California founder or investor counting on the Qualified Small Business Stock exclusion, there is a trap you need to understand before you sell. The California QSBS rules do not follow the federal ones. You can qualify for a 100% federal exclusion under Section 1202, exclude every dollar of gain on your…

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California Residency Audits and the Billionaire Tax: What High-Net-Worth Residents Need to Know
Kugelman Law

California’s proposed billionaire tax has put the California residency audit back in the national spotlight, and made it the single most important issue for wealthy individuals who have recently left the state or are thinking about it. As Proposition 40, the 2026 Billionaire Tax Act, heads toward a statewide vote, the California Franchise Tax Board…

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California Residency Audit: How the FTB Decides If You Really Left
Kugelman Law

A California residency audit is one of the most factually invasive and financially consequential examinations a taxpayer can face. The Franchise Tax Board (FTB) has become aggressive in auditing high-income residents who claim they moved — to Texas, Nevada, Florida, Washington, Tennessee, Wyoming, or anywhere else without a state income tax — and it has…

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Tax Audit Attorney in Marin County, CA: Experienced Representation for IRS and FTB Audits
Kugelman Law

Marin County is home to some of California’s highest earners, most successful entrepreneurs, and most sophisticated investors. It’s also a frequent target for IRS and California Franchise Tax Board (FTB) audit activity. If you’ve received an audit notice at your home in Mill Valley, Tiburon, San Rafael, Sausalito, or anywhere else across Marin, you need…

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