For some time now, California has been the worst state in the country when it comes to exploiting the most tangential of connections to claim tax liability. Recently, the state reasserted its claim to this dubious distinction by attempting to claim the right to tax the sale of partnership interests by nonresidents.

The pace at which taxpayers, both business and individual, have continued to flee the state for greener pastures has only accelerated in recent years. The most recent tax migration data, looking at the difference between tax years 2018 and 2019, finds that California lost over 117,000 taxpaying households and just under $18 billion in adjusted gross income from its tax rolls.One would think California would learn that the way to keep taxpayers from running for the hills would be to create a fairer and more competitive tax code. Unfortunately, the state has instead responded to this trend by ramping up its efforts to catch up out-of-state taxpayers in its tax web.