Prop 40 taxes California residents as of 1 January 2026 on values at 31 December 2026. By the time the vote happens, liability is already determined. Canada’s structure rhymes: emigrating triggers a deemed disposition of most property at fair market value on the day you cease residency — the departure tax. The transferable principle is that tax-driven relocation is priced at the moment you leave, not at the moment you arrive somewhere cheaper, and private-company shares are among the hardest assets to value and fund tax on at that moment. Any structure you want in place for that event has to exist years before it.