News
Colorado Will Tax All Software Sales Starting 2027 Under HB 26-1223
On June 4, 2026, Governor Polis signed House Bill 26-1223 into law. Effective for transactions on and after January 1, 2027, Colorado software sales tax will apply to computer software available for repeated sale or license, no matter how it is delivered. Under prior law, Colorado generally taxed standardized software only when it was delivered…
California Will Tax SaaS Starting 2027: What SB 122 Means for Sellers and Buyers
California has been one of the more favorable states for software transactions when it comes to sales tax. Prewritten software delivered on tangible media has long been taxable, but software delivered electronically or accessed remotely, including software as a service, has generally fallen outside the sales and use tax base. That era is coming to…
From GILTI to NCTI: What the OBBBA Changes Mean for U.S. Multinationals in 2026
Effective for tax years beginning after December 31, 2025, the One Big Beautiful Bill Act (OBBBA) retired the Global Intangible Low-Taxed Income (GILTI) regime introduced by the 2017 Tax Cuts and Jobs Act (TCJA) and replaced it with a revised framework called Net CFC Tested Income (NCTI). While GILTI and NCTI share the same basic…
Global Tax Planning for Employer Of Record Arrangements: Navigating Permanent Establishment Risk
EORs, Global Tax Planning, and the Evolution of International Expansion For U.S. multinationals, global tax planning and international workforce strategy are increasingly intertwined. The employer of record (EOR) model has become a popular alternative to forming a foreign subsidiary or branch at the outset of an expansion. By allowing a third-party provider to serve as…
California Court Opens the Door to Three-Factor Apportionment for Capital-Intensive Businesses
In a decision that could reshape how multistate companies apportion income to California, the Los Angeles County Superior Court ruled in Smithfield Packaged Meats Corp. v. California Franchise Tax Board (No. 21STCV39637) that the taxpayer was entitled to use a three-factor apportionment formula (based on property, payroll, and sales) rather than California’s standard single-sales factor…
IRS Finalizes Form 8308 Part IV Relief for Section 751(a) Partnership Exchanges
Treasury and the IRS are eliminating the requirement to furnish Part IV of Form 8308 to the transferor and transferee in sales of partnership interests where the partnership owns “hot assets.” However, the partnership must still (1) furnish Form 8308 with Parts I–III to the transferor and transferee by January 31 (or, if later, 30…
Indiana Tax Amnesty 2026: No Penalties, No Interest, No Collection Fees Until September 9
If your business or individual clients have unresolved Indiana tax liabilities, the state’s first tax amnesty program in over a decade is offering an unusually favorable path to resolution, but the window is narrow. For the first time in over a decade, Indiana is offering taxpayers a chance to settle outstanding tax debts without the…
Section 1202 QSBS Regulations Are Coming — Here’s What to Document Now
For founders, early employees, and investors in qualifying C corporations, the Section 1202 gain exclusion represents one of the most valuable tax benefits in the U.S. tax code — and it just got bigger. The United States Treasury Department is working with the IRS to develop regulations to implement recent statutory enhancements to the qualified…
The Real Cost of Getting Transfer Pricing Wrong: Five Categories of Exposure
Transfer pricing non-compliance is rarely a single, identifiable event. It tends to compound quietly — an undocumented service arrangement here, an informal loan there — until an audit notice arrives and the full cost of the oversight becomes visible all at once. This guide maps the five categories of cost that practitioners should understand before…
Transfer Pricing for CFOs and Tax Directors: A Compliance Guide for Cross-Border Expansion
The moment your company has a foreign entity and conducts any transaction with it, transfer pricing rules likely apply. This reference covers what triggers compliance, what it requires, and what it costs to get it wrong. There is no de minimis exception for transfer pricing transactions. Every sale of a tangible good, provision of a…
1099-OID vs. 1099-INT: Which Form to Use for Convertible Note Interest Reporting
Many startups issue convertible promissory notes and struggle with which tax form to use to report interest income: Form 1099-OID or Form 1099-INT. Getting it wrong can create compliance issues for both the issuer and the investor. What Is the Difference Between OID and Interest Income? Original Issue Discount (OID) arises when a debt instrument…
KBF State Income Tax Newsletter – 1st Quarter 2026
KBF’s quarterly newsletter updates clients on state and local income/franchise tax news, developments, and trends. Please note that this information is for discussion purposes only and does not constitute specific tax advice. With the passage of the One Big Beautiful Bill Act (OB3), states are now weighing in on how to respond, and their decisions…