Section 351 ETF conversion recharacterized: substance over form under IRS Rev. Rul. 2026-20
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Section 351 ETF conversion: Rev. Rul. 2026-20

Does the Section 351 ETF conversion still work after Rev. Rul. 2026-20? Not the way it has been sold. The IRS now treats a planned transfer of securities to a new ETF followed by an authorized-participant redemption of those same securities as a single taxable exchange, not a tax-free diversification. The Section 351 ETF conversion…

California cybersecurity audit: CCPA Article 9 rule for covered businesses
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California cybersecurity audit: does the CCPA rule apply?

Does the California cybersecurity audit rule apply to my business? A California business is in scope if it either earned at least 50% of its revenue from selling or sharing personal information, or exceeded roughly $26.625 million in annual gross revenue and processed the personal information of at least 250,000 California consumers or households (or…

California digital products sales tax: SaaS and prewritten software become taxable January 1, 2027
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Does California’s digital products sales tax apply to SaaS?

Does California’s digital products sales tax apply to my software business? Starting January 1, 2027, prewritten software — including Software-as-a-Service and remote-access licenses — is a taxable digital product under California’s new digital products sales tax rule enacted by Senate Bill 122. Custom software and several digital-media categories stay outside the rule. A short email…

California employment law and the reach of state statutes over remote workers based out of state

Does California employment law reach remote workers?

Does California employment law reach remote workers based outside the state? Not automatically. In Saberin v. Alation, the California Court of Appeal held that California employment law did not apply where the employee lived in Utah, worked in Utah, and the termination was decided by executives physically located in Illinois — even though the employer…

California tourist tax refund: shopping bags, a receipt, and a passport on a Los Angeles counter
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California tourist tax refund: does it exist? (2026)

Is there a California tourist tax refund for visitors shopping during BTS Week? No. California does not refund sales tax to foreign visitors, and there is no federal program either. A California tourist tax refund does not exist because U.S. sales tax is a single-stage state and local tax, not a value-added tax. The 9.75…

Pop-up shop sales tax: a temporary merch booth near SoFi Stadium with a tablet point-of-sale
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Pop-up shop sales tax in California: what do vendors owe?

What are the pop-up shop sales tax rules for a temporary vendor in California? Get a free CDTFA temporary seller’s permit before the first sale, charge the rate of the city where the customer takes the goods (Inglewood is 10.25 percent, Los Angeles 9.75 percent), pay use tax on giveaways, and file by the date…

Foreign artist withholding: a California promoter's contract and wire form before paying an international act
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Foreign artist withholding in California: who is liable?

Who handles foreign artist withholding when a California venue books an international act? You do. The payer is the withholding agent for 30 percent federal tax on the gross fee and 7 percent California tax on payments over $1,500. Foreign artist withholding drops only when the artist hands you an IRS Central Withholding Agreement letter,…

BTS Week sales spike: a Los Angeles restaurant line near SoFi Stadium and the bookkeeping that follows
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BTS Week sales spike: what changes in your books this month?

What does a BTS Week sales spike change in your books? Four things: your CDTFA sales tax filing frequency can change, tip records must stay clean for the new tip deduction, temporary staff earn daily overtime under California law, and your September 15 estimated tax should stay on the safe harbor. A BTS Week sales…