On July 21, 2026, the California Department of Tax and Fee Administration (CDTFA) held its first implementation workshop meeting regarding Senate Bill 122 (SB 122), which extends California’s sales and use tax to digital software and software-as-a-service (SaaS) effective Jan. 1, 2027. Signed by Gov. Gavin Newsom on June 29, 2026, SB 122 marks the most significant expansion of California’s sales and use tax base in decades.

The workshop drew more than 400 in-person and online participants, and the questions ranged from general scope of the new rules to specific, as-applied fact patterns. The CDTFA offered some clarification, acknowledged that numerous open issues would need to be resolved through emergency regulation, and repeatedly emphasized the limits of its authority — noting that certain relief stakeholders sought would require action by the legislature, rather than the department.

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Photo of Samantha Trencs Samantha Trencs

Samantha Trencs counsels clients on a wide range of state and local tax matters. Samantha’s practice focuses on tax planning, policy, and controversy in virtually all areas of state and local taxation, including income, franchise, sales and use, and property taxes. Her practice…

Samantha Trencs counsels clients on a wide range of state and local tax matters. Samantha’s practice focuses on tax planning, policy, and controversy in virtually all areas of state and local taxation, including income, franchise, sales and use, and property taxes. Her practice also includes advising on multistate audits and litigation matters.

Samantha has deep policy experience, including tracking and monitoring tax legislation and ballot measures to provide in-depth analysis on legislative developments and their impact on Fortune 100 companies. Samantha also has wide-ranging experience researching and analyzing complex sales and use tax issues, including regularly analyzing the applicability of state marketplace collection laws, sales tax holidays, and sales and use tax registration, as well as conducting fifty state taxability studies on key SALT issues.

Photo of Catalina Baron Catalina Baron

Catalina Baron is a member of Greenberg Traurig’s Tax Practice, working out of the firm’s Houston, Dallas, and Austin offices. Catalina has experience with income, franchise, sales and use, partnership and property taxation issues. Her work covers the energy, construction, retail, digital products…

Catalina Baron is a member of Greenberg Traurig’s Tax Practice, working out of the firm’s Houston, Dallas, and Austin offices. Catalina has experience with income, franchise, sales and use, partnership and property taxation issues. Her work covers the energy, construction, retail, digital products, marketplace, equestrian, and real estate industries (among others). Moreover, she has specific experience with respect to Texas matters.

Catalina represents clients through all stages of tax controversy. Catalina also advises on the tax aspects of transactional matters. She has advised clients on issues arising in initial public offerings, mergers and acquisitions, joint ventures, and reorganizations.

Catalina regularly engages with taxpayer associations and organizations advocating for the business industry. She has experience working on multijurisdictional matters.

Catalina closely follows tax-related tax policy and legislative updates, and has participated in advocating for client needs in these environments as well.

Photo of Nikki E. Dobay Nikki E. Dobay

Nikki Dobay serves as a co-chair of the U.S. State and Local Tax (SALT) practice and is nationally known for her deep experience and understanding of state tax policy and the legislative process. She also advises her clients on sophisticated multistate tax issues

Nikki Dobay serves as a co-chair of the U.S. State and Local Tax (SALT) practice and is nationally known for her deep experience and understanding of state tax policy and the legislative process. She also advises her clients on sophisticated multistate tax issues as well as the consequences and planning opportunities related to corporate M&A transactions and oversees state and local tax controversy matters, ranging from audits to appellate litigation, and involving sales and use taxes, income and franchise taxes, property taxes, and constitutional issues.

Nikki regularly engages on key SALT issues impacting multijurisdictional taxpayers with national and statewide business and taxpayer associations, national tax administrator organizations, including the Federation of Tax Administrators (FTA), the Multistate Tax Commission (MTC) and Streamlined Sales Tax (SST), and state legislator organizations, including the National Conference of State Legislatures (NCSL), and the Institute for State Policy Leaders (ISPL). She is also a frequent speaker on a broad array of SALT issues at various conferences across the country, including Council On State Taxation (COST), Tax Executives Institute (TEI), ABA, NYU, Hartman, Deloitte SALT Symposium, and various other regional conferences.

Prior to returning to private practice, Nikki spent five years as senior tax counsel for the COST, a national trade association representing large multistate businesses. While at COST, Nikki focused on the 13 most western states (including Alaska, Arizona, California, Colorado, Hawaii, Idaho, Montana, Nevada, New Mexico, Oregon Utah, Washington and Wyoming), and has a strong working knowledge of the tax regimes in all of these states. Nikki’s time at COST as well as her continual work with state tax administrators through the FTA, MTC and SST have resulted in her having strong relationships with state tax administrators across the country.

Nikki’s broad experience and in-depth knowledge of tax regimes in Oregon, Washington, and Idaho inform her handling of litigation and strategic tax matters in these states. Over the past 20 years, Nikki has consistently worked with taxpayers to address complex state and local tax issues in Oregon, including corporate income excise tax disputes, residency issues, and local tax home rule challenges. She played a pivotal role in drafting Oregon’s Corporate Activity Tax legislation and has represented clients in the Oregon Tax Court on issues ranging from business/non-business income litigation to challenges involving Portland and Metro taxing authority.

In Washington, Nikki advises her clients on all aspects of B&O tax, including handling audits and litigation. She is also involved in efforts to consolidate and streamline B&O tax filing through legislative advocacy and coalition-building, as well as advising clients on sales tax and residency matters. Her work in Idaho includes drafting and successfully passing updated apportionment provisions, as well as advising on corporate tax matters and disputes and legislative initiatives.