CABTANLT143 · MATTER
NLT143·The economy·Worked case study

What California gets when a billionaire stays.
What it loses when they go.

The Walczak / CalTax projection counts dollars (the iceberg below the waterline). The proponent rebuttal counts revenue (the one-time receipt above it). Neither captures the full economic contribution that a billionaire and the companies they build create while resident in California: human capital, financial capital, payroll tax, sales tax, supplier ecosystem, and the follow-on companies their wealth seeds. This page tries to quantify that for one founder. Then it shows what changed when he moved.

◆ The framework: four economic surfaces, not one
Human capital

Direct employees on California payroll. Indirect jobs from suppliers, contractors, and on-campus services. Employee state income tax remits.

Financial capital

Capital deployed into California facilities, R&D, and supplier networks. Property and improvements that anchor a tax base.

Tax surface

Founder personal income tax on stock realizations as a CA resident. Corporate franchise tax. Sales and use tax on operating purchases. Payroll-tied withholdings.

Network effect

The follow-on companies that get founded with proceeds from the first one. The graph of CA founders that came out of CA founders is the most-studied economic-spillover dynamic in the literature.

01 · Worked example

Elon Musk and the four-company stack.

Musk left California for Texas in December 2020. By 2024, all four of his California-built operating companies had relocated their headquarters out of state. California still has the original factories. It has lost the corporate domicile, the future expansion, and most importantly, the founder's personal income-tax surface on future stock realizations.

Direct CA jobs created · 2020
~20,000
Direct CA jobs · today
~27,000
Companies expanded, founder departed
Direct TX jobs · today
~40,000
Net new buildouts since 2020

Read the row carefully: California direct jobs in Musk-companies are higher today than at the moment of the move. The employees stayed and grew. What did not stay was the founder, the headquarters, and the marginal capital deployment for new factories. Texas direct jobs in the same four companies grew from a few hundred (the McGregor engine test site) to roughly forty thousand.

◆ The four companies, side by side

Tesla

Public · TSLA · founded 2003
CA HQ years
2003 to October 2021 (HQ relocation announced at 2021 Annual Meeting)
New HQ
Austin, Texas (Gigafactory Texas / 1 Tesla Road)
CA employees · 2020
~10,000 (Fremont peak production)
CA employees · today
~20,000 across Fremont + Palo Alto + Lathrop (Tesla 2023 10-K, CA-direct)
TX employees · today
~22,000+ at Gigafactory Texas (Austin Chamber and TWC filings 2024)
Latest revenue
$96.8B
✓ Still operates in California
  • Fremont assembly factory (~10M sq ft, the original NUMMI plant Tesla bought in 2010)
  • Palo Alto / Sunnyvale engineering and design offices
  • Lathrop battery and trim facilities
▼ Texas operations
  • Gigafactory Texas, Austin (Cybertruck and Model Y assembly)
  • Headquarters relocated 2022
Sources
  • · Tesla 2023 Annual Report (Form 10-K)
  • · Tesla 2021 Annual Meeting announcement of HQ relocation to Austin (Oct 7 2021)
  • · City of Austin and Travis County economic-development announcements

SpaceX

Private · founded 2002
CA HQ years
2002 to 2024 (HQ relocation to Starbase, TX announced July 2024)
New HQ
Starbase, Texas (Boca Chica)
CA employees · 2020
~6,000 in Hawthorne
CA employees · today
~6,000–8,000 in Hawthorne and Vandenberg
TX employees · today
~3,400 in Starbase + ~1,800 McGregor + Austin Starlink
Latest revenue
~$13B (2023 estimate)
✓ Still operates in California
  • Hawthorne, CA: Falcon 9, Falcon Heavy, Dragon production
  • Vandenberg Space Force Base launch operations
  • Major workforce remains in Hawthorne despite HQ move
▼ Texas operations
  • Starbase / Boca Chica: Starship development and launch
  • McGregor: engine testing facility (since 2003)
  • Austin: Starlink production
Sources
  • · SpaceX HQ relocation filing with TX Secretary of State, July 2024
  • · Hawthorne employer surveys (LA County EDC)
  • · WSJ and Bloomberg private-valuation coverage

The Boring Company

Private · founded 2016
CA HQ years
2016 to 2022 (HQ relocated to Pflugerville/Bastrop, TX in 2022)
New HQ
Bastrop County, Texas
CA employees · 2020
~150
CA employees · today
Negligible
TX employees · today
~250–400
Latest revenue
Not disclosed (private)
✓ Still operates in California
  • Hawthorne test tunnel was built 2017–2018 and demonstrated 2018; physical assets remain but active operations moved
▼ Texas operations
  • Bastrop campus, Pflugerville office
  • Vegas Loop project remains the company's primary deployed product, but engineering moved out of CA
Sources
  • · Bastrop County and TX Comptroller filings
  • · Wired and Bloomberg coverage of Hawthorne to Bastrop relocation

Neuralink

Private · founded 2016
CA HQ years
2016 to 2023 (HQ moved to Austin, TX in 2023)
New HQ
Austin, Texas
CA employees · 2020
~150
CA employees · today
~100–200
TX employees · today
~400+
Latest revenue
De minimis (preclinical product)
✓ Still operates in California
  • Fremont, CA office remains for some R&D
▼ Texas operations
  • Austin HQ and primary R&D
Sources
  • · Neuralink HQ relocation announcements
  • · TX Comptroller filings
  • · Bloomberg / Reuters private-valuation coverage

xAI

Private · founded 2023
CA HQ years
2023 to present (still operates in Bay Area, but X/xAI co-headquarters in Bastrop, TX since 2024)
New HQ
Memphis, TN (compute) and Bastrop, TX (with X)
CA employees · 2020
n/a (didn't exist)
CA employees · today
~100–200
TX employees · today
~200+
Latest revenue
Not disclosed (private)
✓ Still operates in California
  • Some Bay Area engineering operations
▼ Texas operations
  • X / xAI Bastrop campus
Sources
  • · WSJ, Bloomberg coverage of xAI funding rounds
02 · Before and after

What changed in California, what changed in Texas.

Before · 2020
  • Tesla HQ in Palo Alto, IPO'd from CA in 2010, paid CA tax on founder's stock realizations
  • SpaceX HQ in Hawthorne, ~6,000 CA employees, primary US launch site
  • The Boring Company HQ at SpaceX, all engineering in Hawthorne
  • Neuralink HQ in Fremont, all R&D in CA
  • Musk personal residence in Bel Air, CA tax-resident
  • All future Tesla stock option realizations sourced to CA at top marginal rate of 13.3%
After · 2024
  • Tesla HQ in Austin, TX. Fremont continues to operate as factory.
  • SpaceX HQ in Starbase, TX. Hawthorne continues for Falcon 9 and Dragon production.
  • The Boring Company HQ in Bastrop County, TX
  • Neuralink HQ in Austin, TX
  • Musk tax-resident in Texas, no state income tax
  • Future stock realizations largely sourced to TX. CA loses the marginal income-tax claim on the founder.
  • X (the rebranded Twitter) and xAI both headquartered in TX, not CA
03 · The California revenue surface

The taxes that move with the founder, and the ones that stay.

▼ What California loses with the founder

Musk's California-source personal income tax peaked in years he exercised Tesla stock options as a CA resident. Public IRS-disclosed numbers from ProPublica (2021) showed reported taxable income spiking in 2018 (~$1.34M) and 2019 (~$0). Capital gains at California 13.3% top marginal would have been the dominant component when realized.

California-source income tax on Musk now limited to CA-based equity awards and CA-source business income. Federal capital gains realized as a TX resident largely escape California tax.

✓ What California still collects

Tesla, SpaceX, Neuralink, and Boring still operate in California and continue to remit California sales, payroll, and franchise taxes on their CA operations. The HQ move shifts the corporate domicile but does not eliminate California-source receipts.

However, future expansion increments and new facilities tied to these companies have largely landed in Texas, Nevada, and Tennessee since 2021.

04 · The follow-on graph

The new companies a departed founder builds, and where they get built.

The Walczak paper's Ongoing-Loss number depends heavily on this question: when a billionaire who departs starts a new company, where does that company get its corporate domicile, jobs, and tax surface? For the Musk graph since 2020, the answer is mostly Texas, with some Tennessee compute spend (xAI) and some Nevada incorporation.

  • Elon MuskNow: Texas
    • X (the rebranded Twitter, headquartered in Bastrop, TX)
    • xAI (compute deployed in Memphis, TN)
  • Larry EllisonNow: Hawaii / Nashville-area
    • Oracle HQ moved to Austin, TX in 2020. New Oracle HQ in Nashville announced 2024.
    • Lanai investments and life-sciences buildouts in Hawaii.
05 · The corporate exodus, three phases

Before the pandemic, during, and after.

The graph below maps the major California corporate headquarters relocations across three phases. Direct HQ-relocated jobs across all three phases total roughly 52,800. Most of these companies retain operating presence in California (factories, regional offices, manufacturing). The figures below represent jobs that moved with the corporate domicile, not California operations totally vacated.

Pre-pandemic · 2014–2019 · HQ jobs relocated
10,100
Pandemic · 2020–2022 · HQ jobs relocated
33,000
Post-pandemic · 2023–2026 · HQ jobs relocated
9,700
Before March 20202014–2019

Slow but steady. Mostly traditional sectors (oil and gas, food, engineering) relocating to lower-cost states. Pre-COVID baseline outflow.

  • 2014Toyota Motor North AmericaSubsidiary of TM (NYSE)Torrance, CA Plano, TXAutomotive HQ~4,000 jobs
  • 2014Occidental PetroleumOXY (NYSE)Los Angeles, CA Houston, TXOil and gas~1,800 jobs
  • 2016Jacobs EngineeringJ (NYSE)Pasadena, CA Dallas, TXEngineering services~1,200 jobs
  • 2016Jamba JuiceAcquired privateEmeryville, CA Frisco, TXFood and beverage HQ~100 jobs
  • 2017Nestlé USASubsidiary of NESN (SIX)Glendale, CA Arlington, VAConsumer goods HQ~1,200 jobs
  • 2018McKessonMCK (NYSE)San Francisco, CA Las Colinas, TXHealthcare distribution HQ~600 jobs
  • 2019Charles SchwabSCHW (NYSE)San Francisco, CA Westlake, TXFinancial services HQ~1,200 jobs
Pandemic acceleration · Mar 2020 to Dec 20222020–2022

The acceleration. Tech, finance, and capital firms relocate corporate domicile in record numbers. Tesla and Oracle in 2020-2021 are the marquee moves. Roughly 350+ HQ relocations were tracked by Hoover Institution and Stanford during this window.

  • 2020Hewlett Packard EnterpriseHPE (NYSE)San Jose, CA Spring, TXEnterprise tech HQ~1,200 jobs
  • 2020OracleORCL (NYSE)Redwood Shores, CA Austin, TX (later Nashville, TN, in 2024)Enterprise software HQ~8,000 jobs
  • 2020Palantir TechnologiesPLTR (NASDAQ)Palo Alto, CA Denver, COData analytics HQ~600 jobs
  • 20208VC (Joe Lonsdale)PrivateSan Francisco, CA Austin, TXVenture capital~50 jobs
  • 2020CBRE GroupCBRE (NYSE)Los Angeles, CA Dallas, TXCommercial real estate HQ~700 jobs
  • 2020AECOMACM (NYSE)Los Angeles, CA Dallas, TXInfrastructure engineering HQ~600 jobs
  • 2021DXC TechnologyDXC (NYSE)Tysons / El Segundo, CA Ashburn, VAIT services HQ~400 jobs
  • 2021TeslaTSLA (NASDAQ)Palo Alto, CA Austin, TXAutomotive / energy~22,000 jobs
  • 2021Digital RealtyDLR (NYSE)San Francisco, CA Austin, TXData center REIT~200 jobs
  • 2022Stone Brewing (HQ functions)Acquired privateEscondido, CA Richmond, VA (operations split)Brewing~250 jobs
Post-pandemic and pre-CABTA · Jan 2023 to Apr 20262023–2026

Slower pace but more strategically loaded. Musk's remaining companies finish relocating. Chevron leaves after 145 years. The arrival of the CABTA proposal in late 2025 accelerated the calendar for several Musk-era moves.

  • 2023NeuralinkPrivateFremont, CA Austin, TXNeural interface R&D~200 jobs
  • 2024X (formerly Twitter)Private (post-acquisition)San Francisco, CA Bastrop, TXSocial platform~1,500 jobs
  • 2024SpaceXPrivateHawthorne, CA Starbase, TXAerospace~6,000 jobs
  • 2024ChevronCVX (NYSE)San Ramon, CA Houston, TXOil and gas~2,000 jobs
  • 2024Oracle (second move)ORCL (NYSE)Austin, TX Nashville, TNEnterprise software HQn/a

Compiled from SEC 8-K filings, company press releases, state Secretary-of-State filings, and contemporaneous reporting. Employee figures are at-time-of-move estimates. Tax-loss figures are illustrative, derived from public payroll size assumptions and CA top-bracket marginal rates.

06 · Beyond billionaires: who else has been leaving

Six years of net AGI outflow.

IRS Statistics of Income tax-stats migration data tracks every state-to-state move of every filer, by AGI bracket, year over year. California has run a net loss since 2018. The pandemic period (2020-2021) saw the largest single-year outflows in the dataset's history. Cumulative net AGI loss 2018-2023 is over $109 billion.

2018
-$8B
2019
-$8.8B
2020
-$17.5B
2021
-$29.1B
2022
-$23.8B
2023
-$22.5B

Net interstate AGI loss for California, IRS Statistics of Income SOI Tax Stats Migration Data. 2021 was the peak of the Bay Area pandemic outflow. Cumulative 2018–2023 net loss exceeds $109B in AGI.

◆ By income class

The migration is not uniform. Per-capita departure rates climb steeply with income. The headline billionaire-tax debate is one slice of a broader pattern: the higher your AGI, the more likely you are leaving California, and the bigger your dollar footprint when you go.

  • Under $50K AGI
    Net inbound

    Modest net inflow as lower-cost relocations to CA continue, especially for service-sector workers.

  • $50K to $100K AGI
    Net outbound, modest

    Working professionals leaving for lower cost of living; the largest demographic absolute outflow.

  • $100K to $200K AGI
    Net outbound, significant

    Mid-career professionals and small-business owners; largest dollar-weighted outflow group.

  • $200K to $500K AGI
    Net outbound, large

    Senior professionals and specialists; pandemic-era spike in remote-work-eligible departures.

  • $500K to $1M AGI
    Net outbound, very large per capita

    Tech, finance, and medicine. Per-capita departure rate roughly 2x the population average.

  • $1M+ AGI
    Net outbound, severe per capita

    Founder, executive, and capital-gains class. The Walczak paper focuses here. CA top 1% pays roughly half of state personal income tax.

Direction inferred from IRS SOI migration tables and FTB top-bracket filings. Magnitudes vary year to year. The pattern of progressively larger per-capita outflow at higher income brackets is consistent across 2020–2023 data.

07 · Where the money went

California's top ten destinations, 2020-2023.

IRS migration data, weighted average across the four pandemic and post-pandemic years. Texas alone accounts for roughly a quarter of California's outbound AGI. The top three (Texas, Florida, Arizona) account for half. None of the top ten has a state income tax above 7%; six have no state income tax at all.

  • TexasAustin, Houston, Dallas-Fort Worth
    $12B25%
  • FloridaMiami, Tampa, Naples
    $7.9B16%
  • ArizonaPhoenix-Scottsdale
    $4.5B9%
  • NevadaLas Vegas, Reno, Lake Tahoe
    $3.8B8%
  • TennesseeNashville
    $2.7B6%
  • WashingtonSeattle metro
    $2.4B5%
  • IdahoBoise
    $2.2B5%
  • ColoradoDenver-Boulder
    $2.1B4%
  • OregonPortland
    $1.7B4%
  • GeorgiaAtlanta
    $1.5B3%

IRS SOI Tax Stats migration data, weighted average across 2020-2023. Shares are of California's total outbound AGI to other states. Texas alone accounts for roughly a quarter.

08 · The ratios

Billionaires, millionaires, everyone else.

California has 39 million people. About one in 33 households holds at least $1 million in net worth. About one in 184,000 residents is a billionaire. The Act targets the smallest of these populations and aims to fund services for the largest.

39M
Total California population
Census ACS 2023
~1.18M
Millionaire households
UBS Global Wealth Report 2024 / SCF
212
Billionaires
Forbes / Walczak 2026
◆ Headline ratio
1 billionaire per 183,679 Californians

The 2026 Billionaire Tax Act applies to roughly 0.0005% of the population. That base produces, by the proponent estimate, the funding for Medi-Cal and K-14 carve-outs covering the other 99.9995%.

◆ Top 1% ratio
Top 1% AGI threshold ~$760,000

California's top 1% of taxpayers pays roughly 49% of all state personal income tax. The state's revenue base is the most concentrated of any large state. That concentration is the proponent argument and the opposition argument at the same time.

◆ Honest limits of this analysis
Private companies are estimates

SpaceX, The Boring Company, Neuralink, and xAI do not publish employee counts or revenue. Numbers shown are reported ranges from press accounts and city economic-development releases. Treat as directional, not audited.

Counterfactuals are unknowable

What California would look like without these companies, or with them but without the wealth tax, cannot be measured. Only the actual path of jobs, revenue, and HQ moves can.

Causation is contested

Founders relocate for many reasons: tax, regulation, lifestyle, energy, real estate, politics. Attributing the move to any single factor is a judgment call, not a measurement. Texas has been pulling tech founders since well before the wealth-tax proposal.

The base case stayed

Tesla still has Fremont. SpaceX still has Hawthorne. Neuralink still has Fremont. The original factories and engineering centers remain. The HQ move shifts corporate domicile but does not, by itself, eliminate California operations.

What this page is for

Quantify what the projection page narrates.

The Walczak iceberg argument compresses to: future income tax gone with the founder. This page expands it. The answer to “is California losing more than it gains?” depends on the assumption set. Read /scenarios to model the macro path, then come back here for the worked micro-example.

NLT143 · Built by @davidtphung