California Targets Out-of-State Vehicle Tax Avoidance
New law makes California residents personally liable for vehicle taxes held in out-of-state shell companies.
Updated on Oct. 22, 2026 in Taxes

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California enacted Senate Bill 1406 in September 2026 to require residents to pay state taxes on assets held by out-of-state shell companies. The law specifically targets efforts to avoid vehicle registration fees and emissions compliance by using entities based in states like Montana.
Why it matters
This legislation closes a loophole that allowed residents to circumvent California sales tax and registration costs through out-of-state LLCs. By holding partners personally liable for unpaid vehicle taxes, the state aims to increase revenue and ensure compliance with local emissions standards.
Senate Bill 1406 mandates that California residents pay state taxes on assets held in out-of-state shell companies. This measure ensures that local vehicle owners are subject to the same registration fees and emissions laws as other residents.
The players
California
The state government responsible for enacting legislation and enforcing vehicle tax and registration compliance.
The details
The law applies to assets owned by out-of-state shell companies if any partner, manager, or owner is a California resident. It establishes personal liability for LLC partners regarding unpaid vehicle taxes, and nonpayment may be classified as a crime. These changes specifically address the use of out-of-state registrations to bypass California smog checks.
Timeline
September 2026: Senate Bill 1406 took effect.
October 2026: The state enacted the new legislation.
2028: Leno's Law extends smog check exemptions to specific classic vehicles.
Money Landscape
This legislation marks a significant shift in state enforcement by targeting the use of out-of-state shell companies to avoid taxes. It replaces a previous environment where Montana-based entities provided a widely used workaround for California registration fees.
If you hold assets in an out-of-state shell company, you may now face personal liability for California vehicle taxes and registration fees. Consult with a qualified tax professional to review your entity structures and ensure compliance with current state tax regulations.
The takeaway
California residents using out-of-state LLCs to register vehicles must now account for state tax liabilities and smog regulations. Residents should consult with a tax professional to evaluate if their current vehicle registration setup remains compliant under the new law.
Further reading
For more information on state obligations, visit the California Taxes section.
Source note: This article includes information reported by SlashGear.
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