Many California residents wish to avoid paying US capital gains tax and California income tax on their crypto assets, but don’t wish to give up their US citizenship and pay an expatriation tax (to learn more about expatriation tax planning, click here). With Congress and the IRS now taking steps to…
It is a common in my practice to have one spouse become vulnerable to being treated as a California income tax resident, while the other does not. Most often this happens because one spouse remains in California when the other returns home to run a business or work. It can…
In Part I of this Blog entry (click here), we discussed the facts of the Bracamonte Case and some of the observations about them made by the Office of Tax Appeals. In Part II of this Blog entry, we discuss the panels’ remaining observations, what they mean for future domicile changes…
No one who claims to be a nonresident of California wants to receive a letter from the Franchise Tax Board (“FTB”). In most cases, up to that point, you probably thought you were completely off their “radar.” Then comes that day when you receive a form letter (i.e., FTB Form…
For California income tax purposes, a person has their domicile in California if, at any point: (a) California has become their true, fixed and permanent home where they have their most settled and permanent connections; and (b) they have not effectively changed their place of domicile to a new location thereafter. To change…
Whether you are a U.S. or foreign citizen, if you have lived in California as a tax resident for any period of time, unshackling yourself from the California tax authorities when you want to leave can be a very tricky affair. The California tax authorities do not relinquish jurisdiction to…
(and why you should care) If you spend a considerable period of time in California each year and have developed significant contacts here you should be asking yourself this question. The State of California is hungry for tax revenue and believes that people who are present in California enjoying the benefits of all California…