State and Local Tax Policy to Watch in 2nd Half of 2026

State and Local Tax (SALT) Team Co-Chair Logan Gans was featured in a Law360 article previewing the top state and local tax policy issues to watch during the second half of 2026. The article covered matters including rollbacks of exemptions for data centers and a potential restructuring of Florida property taxes. Mr. Gans commented on California's proposed wealth tax, a one-time 5 percent levy on the assets of state residents whose net worth exceeds $1 billion. Supporters of the measure argue it will raise billions in funding for healthcare and education, whereas opponents contend those estimates are exaggerated and the tax could instead push wealthy investors out of the Golden State. Mr. Gans, who advises high-net-worth individuals covered by the tax, highlighted it applies retroactive to January 1, 2026, which could lead to disputes over whether a billionaire who left California did so in time to establish residency elsewhere. He added he tells clients the general rule is the more they cut ties with a state, the more persuasively they can argue they are no longer subject to that state's jurisdiction and thus do not have to pay a tax like this one. It's not always that simple, however, he acknowledged, and even if voters approve the tax come November, it will likely face a bumpy rollout.

"Some people want to keep their doctors, lawyers and accountants in their prior state, and some of those factors do play a role sometimes" in domicile determinations, he explained. "...If it passes, between potential court challenges and implementation issues, it's probably not going to be a smooth process."

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