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.
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