I gotta ask you, because this has been eating me since I read it. It appears you've been on HN even longer than me, so I trust you know what you're talking about. I left California in 2006 and moved overseas, never established residency in another state, lived outside the country for 12 years before coming back and establishing residency in Oregon. During that time I did file federal taxes, but most of my income fell under the foreign earned income exemption (< $95k when I left). I did pay social security. But I was no longer considering myself a California resident. Are you saying that California is now trying to claw in taxes from people who left the state 16 years ago and earned foreign income, if they didn't immediately establish residence elsewhere in the US? -- FWIW, I did also skate on visas for those 12 years and never established permanent residency in another country, but nonetheless I wasn't living or making money in California, or intending to return there.