Expert Report on Valuation of Controlling Shares of Publicly Traded Companies Under the California Billionaire Tax Act (CBTA)

Authors

David Gamage, University of Missouri School of Law
Brian D. Galle
Emmanuel Saez
Darien Shanske

Document Type

Article

Publication Date

2026

Abstract

This short memo addresses concerns that have been raised under the proposed California Billionaire Tax Act (CBTA or Act) about the valuation of "voting" or "special control" shares, particularly with regard to shares held in publicly traded companies. A misreading of the CBTA is circulating that claims that voting shares of all assets will be taxed in full regardless of their actual value. This is false, as shown by a straightforward reading about the provision relating to voting and special control shares in context.

Recommended Citation

David Gamage et al., Expert Report on Valuation of Controlling Shares of Publicly Traded Companies Under the California Billionaire Tax Act (CBTA)University of Missouri School of Law Legal Studies Research Paper No. 2026-04 (2026).
Available at: https://scholarship.law.missouri.edu/facpubs/1349