Disclosure: I own a house in Spearfish, South Dakota that is currently on the market. The listing is referenced by address later in this article. The argument I'm making here is one I've made with my own money — and one I'm asking the reader to evaluate as both an analytical claim and a transaction I have a stake in. I think the case stands either way.
You may not be a billionaire. But you could, in this particular moment, be smarter than several of them.
The wave of California-based wealth currently relocating to Lake Tahoe's Nevada shore — chronicled at length in this publication by my colleague Eli Rosenberg — is being treated by most observers as a sophisticated tax-planning move. It is not. It is a herd movement, and the herd is running in the wrong direction.
Sergey Brin paid $42 million for a 5.14-acre estate in Incline Village in December 2025, less than 1,000 feet from the California border. Steve Jurvetson paid $125 million for a neighboring compound in March 2026, plus another $53 million in adjacent properties — a $178 million Incline Village commitment. Larry Ellison bought the entire Hyatt Regency property for $345 million in 2021. Naveen Rao, founder of an AI startup recently valued at $4.5 billion, told Rosenberg that he closed on a $20 million Incline mansion in under thirty days because he feared the proposed California billionaire tax would force him to liquidate his startup equity. "My company will die or I'm insolvent," Rao said.
Rao's fear is real. The proposed initiative, which is expected to qualify for the November 2026 ballot, would impose a one-time 5% levy on net worth above $1 billion for anyone who was a California resident on January 1, 2026 — a retroactivity provision specifically designed to defeat the kind of move Rao made. Whether the tax passes, whether it survives constitutional challenge, and whether collection ever begins are open questions that will play out over the next several years. The buyers fleeing into Incline Village are betting it will. Fine. That is a defensible bet.
What is not defensible is the destination they chose.
The Per-Acre Arithmetic
Incline Village is a town of 9,200 people on the Nevada side of Lake Tahoe. It has no state income tax. Neither does Nevada more broadly, which is why Larry Ellison and Workday's David Duffield have lived there for years, and why a steady trickle of wealthy Californians have made the same move for decades. The recent migration has turned the trickle into a flood. Three luxury estates over $20 million sold in Incline in the entirety of 2024. Through April 2026, the town had already matched that total in four months.
The pricing on Incline Village land has, accordingly, gone vertical. Brin paid roughly $8.2 million per acre. The current Sandy Shores listing is asking $25.7 million per acre. Jurvetson paid approximately $83 million per acre — a number that would price the empty dirt under Manhattan's Central Park at over $70 billion if the same rate applied. Bill Dietz, the Tahoe Luxury Properties broker who sold Sandy Shores' previous comparables, told SFGATE that the California tax savings are large enough to retire the cost of the lakefront. "It's not a rounding error," he said. "It's mind-boggling that way."
Dietz is correct that the math works. He is incorrect that the math is impressive. What he's describing is a buyer who saved $20 million in California taxes and spent $40 million more than necessary on land to do it. The savings are real. The premium is also real. The premium is twice the savings.
The buyer who flees California's 13.3% top income tax rate has, fundamentally, two destinations available to them in the United States: Nevada and South Dakota. (Wyoming, Texas, Florida, and a handful of others also have no income tax, but only Nevada and South Dakota combine that with the trust-jurisdiction infrastructure that this particular cohort actually needs.) Both states deliver the same income tax outcome. Neither has a state income tax, capital gains tax, estate tax, or inheritance tax. From a federal-residency-test perspective, either state's domicile claim is equally defensible. The Tahoe migrators chose the more expensive of the two by a factor of roughly 250.
Why South Dakota Is the Better Destination
The Tahoe migration overlooks something else, which is that South Dakota has the better trust regime. Trusts & Estates magazine has ranked South Dakota the #1 trust jurisdiction in the United States in all categories for both 2024 and 2025 — ahead of Nevada, ahead of Delaware, ahead of every other state. South Dakota abolished the Rule Against Perpetuities in 1983, the first state to do so, which means a dynasty trust established here can preserve wealth across unlimited generations without ever being forced to distribute or terminate. Court filings related to South Dakota trusts are automatically and permanently sealed; the privacy regime is the strongest in the country. Self-settled domestic asset protection trusts are permitted, with the grantor allowed to remain a discretionary beneficiary.
For a Brin or a Jurvetson — or a Rao, who has billions in pre-IPO equity that needs to be planned around generationally — South Dakota is, on paper, the better destination. The Tahoe cohort either doesn't know this or doesn't care, and the reason they don't care is the part of the migration that should be most embarrassing to admit out loud: they are following each other.
Matthew Nordby, who runs a venture fund in Incline Village, told Rosenberg the area is becoming "the Hamptons of San Francisco" and "an alternative to Sand Hill Road." That is the actual pitch. Not lower taxes. Not better trust law. Not privacy or asset protection. The pitch is proximity to the same peer group everyone moved away from California to escape from. The buyers are paying an 80-fold per-acre premium over the next-best alternative for the privilege of being clustered with each other in a 9,200-person town with a finite number of restaurants.
Jennifer Tiexiera, a filmmaker who's lived in Incline Village for two decades, told Rosenberg that nobody has actually seen Larry Ellison since he bought the Hyatt for $345 million. "We know he bought everything," she said, "but that's about it." That sentence is the entire Incline Village proposition in miniature. The wealthy moved there to escape and did not, in fact, escape. They bought houses they don't visit, in a town crowded with people they were trying to leave behind, on land priced as if it were the last buildable acreage on Earth.
What the Smart Version of This Trade Looks Like
I will now tell you what the smart version of this trade looks like, because I made it.
In 2024, I had a 4,000-square-foot contemporary residence built on two acres in Spearfish, South Dakota, designed from the collection of California architect Mark Singer. The address is 2111 Vantage Circle. It is currently listed at $2 million.
The land cost me $100,000 per acre — approximately one one-thousandth of what Steve Jurvetson paid for the dirt under his Incline Village compound, and one eighty-second of what Sergey Brin paid for his. At Jurvetson's rate, the empty land beneath my house would be valued at $166 million; the 4,000-square-foot Singer-designed home sitting on it would, in that arithmetic, be a rounding error on the closing costs.
The house has 270-degree views across three states — South Dakota, North Dakota, and Wyoming. The nearest neighbor is a mile away. Black Hills Airport, a fully jet-capable private aviation field with a 6,400-foot runway, is three miles as the crow flies; the drive from the tarmac to my front door takes five minutes, on flat road, in any weather. Terry Peak Ski Area — thirty groomed runs — is six miles away. The town of Spearfish, with Black Hills State University and a Monument Health hospital that is a member of the Mayo Clinic Care Network, is under five minutes in the other direction.
San Francisco is approximately two hours and ten minutes away by mid-size jet. Los Angeles, two and a half. New York, three and a quarter. Chicago, under two. Denver, fifty minutes. Bozeman and Jackson Hole, both under an hour. Spearfish sits in the geographic center of the United States, which means that from this airport three miles from this house, every major American business center is reachable in under three and a half hours.
The Incline Village pitch, as Rosenberg reports it, rests on a single number: forty minutes by jet from Truckee to the Bay Area. That number is real, and for a daily-commuter executive — someone who needs to be in San Francisco three times a week — it is meaningful. For everyone else, which is to say for most of the people who actually moved to Incline Village, the difference between a forty-minute flight and a two-hour-ten-minute flight is, amortized over a once-a-week or once-a-month meeting cadence, an hour each way. For that hour, the Tahoe cohort is paying roughly an 80-fold per-acre premium. That is the most expensive hour in American business aviation.
And the Tahoe forty-minute flight comes with a hidden tax that the brochures don't mention: the twenty-five-minute drive from Truckee airport to Incline Village, on Highway 267 or 28, at 7,000 feet of elevation, on roads that close intermittently from October through April for snow, ice, and avalanche control. Wildfire season closes the Truckee airport entirely several weeks each summer. From Black Hills Airport to my driveway, the drive is five minutes, and runs past a few pheasants and a small herd of cattle.
What the Migration Is Actually For
None of this is a secret. The South Dakota trust regime is well-documented. The land prices in the Black Hills are public. The flight times are arithmetic. The fact that the Tahoe migration ignored all of it tells you something about what the migration is actually for.
Naveen Rao is not stupid. He is a successful AI founder running a company valued at $4.5 billion. When he told Rosenberg that the proposed billionaire tax could force him to liquidate his equity and bankrupt his startup, he was describing a real problem, and his decision to leave California in response was rational. What was not rational was the destination he chose, in thirty days, with what reads in the Rosenberg piece as something close to panic. He found a $20 million house in Incline Village and closed in ten days. He did not spend those ten days asking whether Nevada was the right state. He spent them asking which Incline Village house had a movie theater big enough.
The wealthy people fleeing California's billionaire tax made the move quickly, made it expensively, and made it to the wrong place. They did so because the wrong place was where their friends were going.
This is the part of the story that is most damning, and that Rosenberg's piece, which was a beautifully reported real-estate feature, was not designed to ask: the wealthy people fleeing California's billionaire tax made the move quickly, made it expensively, and made it to the wrong place. They did so because the wrong place was where their friends were going. The peer-pressure premium they paid for that is, as far as I can tell, the largest single consumer-luxury markup in the contemporary American economy. They could have routed around it.
They did not route around it because they did not stop to think.
The Offer the Title Is Making
Here, then, is the offer the title of this piece is making, in its most literal form. There is a house at 2111 Vantage Circle in Spearfish, South Dakota, on two acres, with three-state views from a 270-degree deck, designed by a California architect, fully furnished and ready for immediate occupancy, three miles from a jet-capable airport, six miles from a ski mountain, a mile from the nearest neighbor, in a state with no income tax and the best trust laws in the country. It is listed at $2 million. The arithmetic that says the Incline Village cohort overpaid by one to two orders of magnitude does not require you to buy this particular house to be true. It requires you only to look at the numbers.
You may not be a billionaire. But the number of people in the position of needing to make this decision — California-based wealth, exposed to the proposed tax, considering a relocation, capable of evaluating an alternative — is not small, and most of them have not yet been told that an alternative exists. The Tahoe brokers will not tell them. The Incline Village social network will not tell them. The peer group that will surround them at the new location will reinforce, not interrogate, the choice.
So here, in The Information, is the alternative being told. The pheasants and the cattle do not know what their land is worth in California-tax-refugee dollars. They know what it is worth in pheasant and cattle dollars. The buyer who can hear that distinction, and act on it, is the buyer who routed around the herd.
The herd, meanwhile, will keep buying Incline Village. The peer-pressure premium will keep climbing. Steve Jurvetson set a Tahoe record in March at $125 million. Someone will pay more before the year is out. The Information will report on it. The cycle will continue.
The reader of this piece, who is paying attention, will not be in that cycle.
Don't lament. Engage.