THE BILLIONAIRE TAX VS. THE OFFSHORE TRUST: INSIDE CALIFORNIA’S PROP 40 AND WEALTH PROTECTION
The landscape of ultra-high-net-worth individuals in California is facing a massive legal shift. On November 3, 2026, voters will decide on Proposition 40 – the 2026 Billionaire Tax Act.
If passed, Proposition 40 will impose a one-time 5% excise tax on the worldwide net worth of California residents and applicable trusts valued at $1 billion or more. Because this tax targets wealth globally, many are asking a critical question: can offshore asset protection structures shield wealth from a state-level wealth tax?
The short answer is NO!