On Sept. 10, 2026, the California Department of Tax and Fee Administration (CDTFA) held its second Interested Parties Meeting to discuss proposed emergency regulations implementing state Senate Bill 122 (SB 122), which will extend California sales and use tax to prewritten software and software as a service (SaaS) beginning Jan. 1, 2027.

While the proposed regulations provide a roadmap for implementation, the discussion underscored that impacted parties have remaining questions regarding sourcing, contract-transition rules, multistate software deployment, and the administration of SB 122’s direct-pay and multiple-points-of-use (MPU) provisions.

Click here to read the full GT Alert.

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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.

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Will Fox

Will Fox is an Associate in Greenberg Traurig’s Washington, D.C. office and is a member of the firm’s U.S. State and Local Tax (SALT) practice. Will focuses his practice on multistate income and franchise tax matters, including nexus, apportionment and sourcing, combined reporting…

Will Fox is an Associate in Greenberg Traurig’s Washington, D.C. office and is a member of the firm’s U.S. State and Local Tax (SALT) practice. Will focuses his practice on multistate income and franchise tax matters, including nexus, apportionment and sourcing, combined reporting, pass-through entity taxation, and federal-state tax conformity.

Will regularly advises multistate businesses on state tax planning and controversy matters, including filing positions, refund claims, and the application of constitutional and federal limitations on state taxing authority.

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Photo of Bradley R. Marsh Bradley R. Marsh

Bradley R. Marsh is Co-Managing Shareholder of the San Francisco office and focuses his practice on tax controversy matters, including property, sales, payroll, business license, employment, franchise, parcel, district, documentary transfer, transient occupancy, utility user, income, parking, gift and estate taxes. He serves…

Bradley R. Marsh is Co-Managing Shareholder of the San Francisco office and focuses his practice on tax controversy matters, including property, sales, payroll, business license, employment, franchise, parcel, district, documentary transfer, transient occupancy, utility user, income, parking, gift and estate taxes. He serves as a co-chair of the State and Local Tax (SALT) Practice. Brad represents clients in audits, litigation and administrative hearings, as well as analyzing transactions and business models, and developing strategies for legislative resolutions.

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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.

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