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Wealth Planning, Financial Planning, Estate Planning

Yikes! California’s Proposed Billionaire Tax!

Published: March 11, 2026
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Why should a second residency be prepared early?

Periods of political change, regulatory uncertainty, and accelerated wealth creation increasingly influence how founders, investors, and families evaluate residency and long-term planning considerations. From a Swiss-based global wealth-planning perspective, experience suggests that maintaining optionality, such as having a second residency prepared in advance, can support more orderly planning discussions. Recent policy proposals, including California’s proposed billionaire tax, have contributed to greater interest in early, internationally coordinated planning rather than time-compressed responses.

Why do policy developments highlight the importance of advance preparation?

We are often contacted following major policy announcements or regulatory proposals. These moments typically reveal existing planning constraints rather than create new ones.

California’s proposed billionaire tax, applicable to residents with net worth above USD 1 B and anchored to January 1, 2026, illustrates how policy design can limit flexibility after implementation. More broadly, such developments underscore the importance of having residency options and asset structures established in advance, rather than attempting to implement changes once timelines are compressed.

Why is establishing a second residency viewed as a long-term planning consideration?

Residency is not determined by a single action. Jurisdictions such as California apply a “closest connection” standard, assessing where an individual’s life is substantively centered, including family, business activities, assets, social ties, and demonstrated intent.

As a result, some internationally active individuals consider establishing a second residency well in advance, even if no immediate relocation is planned. This preparation may include increased interest in acquiring residential property abroad, which can support future lifestyle flexibility and provide evidence of ongoing ties to another jurisdiction. Property ownership alone, however, does not determine residency status.

What tax obligations remain when residency changes?

It is important to distinguish residency from taxation. For US citizens and certain long-term residents, US tax obligations continue regardless of where domicile or residency is established, even outside the United States.

International planning does not eliminate tax obligations. Instead, it focuses on coordinating residency, asset ownership, and estate structures within applicable tax and reporting frameworks. Any planning should be evaluated in light of current laws and individual circumstances.

Why is international wealth planning described as an architectural process?

International wealth planning is typically approached as a structured, multi-year process rather than a tactical response. It may involve:

  • second residency preparedness
  • jurisdictional diversification
  • asset-holding and ownership structures
  • pre-liquidity considerations
  • family governance and succession planning

These elements require sequencing, documentation, and consistency over time. While political outcomes and legal interpretations may evolve, relying on future changes is not a substitute for disciplined, forward-looking planning.

Frequently Asked Questions

Is establishing a second residency only relevant if relocation is imminent?

No. Some individuals view a second residency as a form of long-term optionality rather than an immediate move.

Does leaving California or the US end US tax obligations?

No. US citizens and certain residents generally remain subject to US taxation on worldwide income, at least the US Federal tax.

Why are more individuals considering property purchases abroad?

Property ownership may support lifestyle planning and future residency considerations, subject to local laws and tax treatment.

When is it appropriate to begin international planning discussions?

Planning is often more effective when considered before major liquidity events, policy changes, or personal transitions.

Summary

Current policy discussions have reinforced the value of preparation over reaction. Establishing a second residency, coordinating global assets, and understanding ongoing tax obligations are increasingly viewed as components of longer-term planning conversations. In an environment of regulatory change and accelerated wealth creation, early preparation can help preserve flexibility, while outcomes remain dependent on individual circumstances and applicable law.

Source:

About the Author

This article reflects the perspective of Alpen, a Swiss-based financial advisor and global wealth planner advising internationally active individuals and families on second residency planning, jurisdictional diversification, and cross-border structuring considerations in addition to traditional wealth management services.
Alpen Partners and Alpen Partners International are licensed by FINMA, the Swiss Financial Market Supervisory Authority, as a portfolio manager.
Alpen Partners is licensed throughout Canada as a portfolio manager.
Alpen Partners International is registered with the SEC in the United States as an investment advisor.
All investments involve certain risks. All investments carry the potential for financial loss, including the loss of the principal amount invested. Past performance is not an indicator of future results.

Market conditions and broader economic factors can significantly impact the value of investments. Investments in international markets are subject to additional risks, such as currency exchange fluctuations, political or economic instability, and variations in accounting practices. Alternative investments, including but not limited to hedge funds, private equity, and real estate, may be illiquid, speculative, and are not suitable for all investors.

The above information should be considered before making any investment decisions.

All posts and publications are for your information only and are not intended as an offer, promotion, or solicitation to buy or sell any financial instrument or perform any other financial transactions. All information and opinions expressed in posts and publications reflect our current views as of the date of the publication and may be liable to change without notice.

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Wealth Management

Following the establishment of his Swiss banking structure, David required a coordinated framework to manage assets across jurisdictions while maintaining compliance with U.S. reporting obligations.

Alpen integrated his assets into a Swiss wealth management structure tailored for internationally active clients. The focus was on aligning investment strategy, currency exposure, and financial planning within a single cross-border framework.

Through Alpen’s wealth management services, David gained access to

  • Global investment advisory, allowing participation in international markets while considering U.S. regulatory requirements
  • Multi-currency portfolio management, reducing reliance on a single currency exposure
  • Cross-border financial planning, supporting his relocation and long-term wealth objectives
  • Centralized oversight of assets held with Swiss custodian banks

Switzerland’s stable political environment, strong financial sector, and long-standing expertise in wealth management provided a reliable foundation for administering David’s international assets.

Offshore Banking Structure

With the Swiss account in place, Alpen integrated it into a broader offshore banking structure designed for diversification and asset protection.

This framework allowed David to

  • Hold assets across multiple currencies
  • Access international investment opportunities
  • Diversify assets outside a single jurisdiction
  • Ensure the highest standards of financial privacy while maintaining full transparency for international reporting

The Swiss banking environment also offered political stability, robust financial regulation, and a historically strong currency base.

Relocation and Swiss Residency Path

As part of his relocation planning, David explored the process of establishing residency in Switzerland. For non-EU citizens such as U.S. nationals, residency typically requires either employment in Switzerland, the establishment of a local company, or a negotiated tax arrangement with cantonal authorities.

Working alongside local legal and tax advisors, Alpen helped David evaluate the available options and coordinate the financial aspects of the move. This included aligning banking structures, documenting international assets, and preparing financial disclosures required during the residency process.

Swiss Bank Account Setup

Opening a Swiss bank account as a U.S. client follows a defined onboarding process based on regulatory requirements and internal bank standards. This includes identity verification, source-of-wealth documentation, and alignment with international reporting frameworks. It also involves coordination with the selected institution, including the negotiation of account terms and applicable fee structures.

Alpen supported David throughout this process by coordinating each step

  • Assessing eligibility and identifying Swiss private banks experienced with U.S. clients
  • Preparing and reviewing required documentation, including passport verification, financial history, and source-of-funds evidence
  • Advising on account structures (e.g. personal vs. investment accounts) aligned with his objectives
  • Coordinating communication with the selected bank and managing the submission process

As part of the onboarding, David was required to provide detailed documentation regarding his financial background and the origin of his assets. Minimum deposit thresholds and internal bank criteria were also considered when selecting the appropriate institution.

Once all documentation was complete and approved, the account opening process typically took approximately 1–2 weeks. Alpen then coordinated the initial asset transfers and ensured a smooth transition from existing banking relationships.