State tax changes, tax swaps, and emerging revenue proposals may affect the tax landscape for multistate businesses.
Continue Reading Tax Swaps and New Revenue Raisers: How State Tax Changes Might Impact Businesses
California OTA Rejects FTB’s IRC Section 751 Partnership Sourcing Theory
In a significant development for nonresident investors and private equity structures, the California Office of Tax Appeals (OTA) held that gain attributable to IRC section 751(a) “hot assets,” such as unrealized receivables and inventory items, remain part of the sale of a partnership interest. As the sale of an intangible interest, the sale of partnership
GeTtin’ SALTy Episode 85 | EPR Litigation Update: Oregon Court Upholds Packaging Law as Challenges Continue
In GeTtin’ SALTy Episode 85, Nikki Dobay and Madeline Orlando discuss recent litigation involving state packaging extended producer responsibility laws and the potential implications for businesses subject to emerging EPR programs.
GeTtin’ SALTy Episode 84 | California’s New Digital Tax: Navigating Sales Tax on SaaS and Software
In GeTtin’ SALTy Episode 84, Nikki Dobay and Samantha Trencs discuss California Senate Bill 122, its expansion of sales tax to certain software and digital products, and related compliance considerations for businesses.
CDTFA Addresses Stakeholder Questions on California’s SB 122 Software and SaaS Tax
California’s CDTFA addressed stakeholder questions on proposed SB 122 regulations, including software and SaaS tax sourcing, MPU rules, contract transitions, and compliance ahead of the Jan. 1, 2027, effective date.
Continue Reading CDTFA Addresses Stakeholder Questions on California’s SB 122 Software and SaaS Tax
California Office of Tax Appeals Rejects Unitary Business Treatment for Gain from Sale of Company Division
In a pending precedential decision, the California Office of Tax Appeals held that gain from the sale of a beverage distribution division was not apportionable to California because the division was not part of a unitary business.
Continue Reading California Office of Tax Appeals Rejects Unitary Business Treatment for Gain from Sale of Company Division
California SB 122 – CDTFA Workshop Addresses Software and SaaS Tax Rules Effective Jan. 1, 2027
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.
GeTtin’ SALTy Episode 78 | California Dreamin’ of More Taxes: Budget Surprises, Taxation of SaaS, and a Crowded Ballot
California’s tax landscape is shifting fast. This episode breaks down Governor Newsom’s newly signed budget, including a SaaS sales tax and credit limitations, alongside the ballot measures California voters will face in 2026 – from a proposed billionaire wealth tax to a personal income tax surcharge extension.
California Advances Budget Trailer Bill to Tax Software, SaaS, and Limit Business Credits
A California budget trailer bill would extend sales tax to software and SaaS and adjust business credit limits, with potential implications for tax planning and compliance.
2 Tax Measures, 1 Ballot: San Francisco Parcel Tax, Regional Sales Tax Move Forward
Two tax measures aimed at addressing transit funding shortfalls in San Francisco and the surrounding region have gathered enough signatures to potentially qualify for the November 3, 2026, ballot. Property owners, commercial tenants, and consumers across five Bay Area counties may wish to monitor developments as certification proceeds and final ballot language takes shape.
Continue Reading 2 Tax Measures, 1 Ballot: San Francisco Parcel Tax, Regional Sales Tax Move Forward