I'm employed at a private company in San Francisco. Part of my compensation is in RSUs, which are subject to the standard two vesting conditions for startup company stock: time, and the occurrence of a liquidity event. That means the stock doesn't actually vest until an IPO or acquisition. At the time of IPO, when the RSUs are converted to shares in the company, I will owe income tax on the total number of RSUs vested times the opening share price.
If I move out of California and terminate my employment with the company before the IPO, will I owe income tax to California since the RSUs were granted while I was working in California? Or will I owe income tax to my new home state, since the actual taxable income occurs while I am living in the new state?
I found a similar situation, described in https://www.ftb.ca.gov/law/ccr/2013_02.pdf
The difference is that in this case, the person was still employed at the time of IPO.