Moving before the residency test date
Does not transfer — it invertsBrin and Page apparently got in front of a 1 January 2026 residency test by leaving in 2025. That works because California’s measure, as reported, taxes presence on a date. Canada does the opposite. Under section 128.1 of the Income Tax Act, emigrating triggers a deemed disposition of most property at fair market value — departure tax — so leaving is itself the taxable event. Private-company shares are generally caught; some property can be deferred against security, and treaties and a step-up in the new country matter. The California lesson is “leave before the date.” The Canadian lesson is that there is no date to beat, only a toll on the way out, and planning that ignores the difference points exactly backwards.