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Seems kind of pointless. If they wanted to they could just decide a retroactive date from when the law is in action.
Those would have robust constitutional challenges.
What constitution?
Unless there have been updates, this is the current text:

https://oag.ca.gov/system/files/initiatives/pdfs/25-0024A1%2...

It applies only to tax year 2026. Leaving before January avoids the tax; becoming a billionaire after Dec 31, 2026 also avoids the tax.

If this passes, I suspect you are going to see as many shenanigans as people can get away with to delay any sort of valuation process that marks someone as a billionaire. No VC rounds with higher valuations in the second half of 2026?

Remember the saying about being greedy when others are fearful?

Thinking about starting a business to teach billionaires that when you have billion(s) of dollars you can live wherever you want and then like you can also have a house (or just rent one) in a completely different place. this first place where you “live” would be some place that is advantageous to you in terms of taxes and general civil services etc and these other places can be where you actually want to reside.

Planning on charging $10 million for initial consultation to explain this concept and then $1 million per month in ongoing consultation fees

Some states like NY have that issue with snow birds moving to Florida for part of the year.

As long as you lived in the low tax state and didn't reside in the high tax state for the majority of the year it could work.

1. https://nypost.com/2025/12/29/us-news/nys-snowbirds-lose-bid...

In other news, yet another billionaire doesn’t want to pay his fair share of taxes.