Tax Migration

California's Two New Taxes for 2027: What SB 122 and SB 125 Actually Cost You (and the One Tax Cut Sacramento Can't Block)

19 min read

On June 29, 2026, Governor Newsom signed a budget that creates two new taxes effective January 1, 2027: a sales tax on software and SaaS (SB 122) and a redesigned health plan tax (SB 125) that is expected to flow into private premiums. This guide breaks down exactly what each tax covers, what is exempt, what a real household will pay, and why the sourcing rule in SB 122 makes your address the deciding factor. It also covers what it actually takes to move your domicile to a state that taxes neither your software nor your income.

Editorial illustration in navy and teal showing a stylized map with a travel route between two location pins, representing Californians relocating to Florida ahead of the two new California taxes taking effect January 1, 2027
YTBET
Your Tax Base Editorial TeamCalifornia Exit & Florida Domicile Specialists

The Your Tax Base Editorial Team helps Californians, remote workers, and mobile professionals legally establish Florida domicile and defend it against former-state audits. All content is researched against primary sources: chaptered California legislation, Legislative Analyst’s Office reports, Franchise Tax Board guidance, and Florida statutes and Department of Revenue advisements.

Reviewed against primary state authorities, including California SB 122 (Stats. 2026, taxation trailer bill; digital products effective January 1, 2027), California SB 125 (Stats. 2026, Ch. 24; Medi-Cal managed care organization provider tax), the Legislative Analyst’s Office EconTax analysis of the prewritten software sales tax, Florida Technical Assistance Advisement 16A-014 (electronically delivered software), and Florida Statutes §222.17 (Declaration of Domicile).

Quick Summary

On June 29, 2026, California enacted two new taxes that take effect January 1, 2027. SB 122 extends the state’s sales tax (7.25% base plus local district rates) to prewritten software and SaaS however it is delivered, including downloads, subscriptions, and remote access. It is expected to raise roughly $900 million a year for the state general fund plus about $1.1 billion for local governments once fully phased in. SB 125 rebuilds the managed care organization tax at $8.85 per enrollee per month on private health plans; if insurers pass it through, the Legislative Analyst’s Office puts the impact at roughly a 1.5% premium increase, around $400 a year for a family of four. A California Taxpayers Association spokesperson called the package the largest tax increase in state history in dollar terms. For most households the two new taxes add hundreds, not thousands, per year, and that is exactly the point: they land on top of a 13.3% top income tax rate that already costs high earners tens of thousands annually. SB 122’s own sourcing rule ties the tax to the purchaser’s address, which means the one lever Sacramento cannot pull is where you are domiciled. Florida taxes neither electronically delivered software nor personal income, and its constitution is built to keep it that way.

Key Takeaways

1

Two new taxes are law, effective January 1, 2027

Governor Newsom signed the 2026–27 budget on June 29, 2026. SB 122 extends sales tax to digital prewritten software and SaaS; SB 125 rebuilds the managed care organization (MCO) tax on health plans. Both were chaptered the same day.

2

SB 122 taxes software however it reaches you

Downloads, subscriptions, and remotely accessed SaaS all become taxable tangible personal property on January 1, 2027, at the 7.25% statewide base plus local district rates. Custom-built software stays exempt. The state expects about $900 million a year for the general fund plus roughly $1.1 billion for local governments.

3

Streaming, games, and ebooks are NOT taxed, despite the headlines

SB 122 explicitly excludes video games, audio and audiovisual works, books, visual works, and digital assets. Netflix, Spotify, and your game library are outside the new tax. The tax lands on the working stack: design suites, office software, tax prep, cloud tools.

4

SB 125 adds $8.85 per enrollee per month to private health plans

The redesigned MCO tax applies for 2027–2029 and needs federal CMS approval before collection. The Legislative Analyst’s Office expects roughly a 1.5% premium bump if plans pass the cost through, which means a family of four could pay around $400 more per year.

5

The dollar figures are small by design; the trajectory is the story

A typical household might pay $300–$600 a year across both taxes. That is the marginal cost. It stacks on a 13.3% top income tax rate (14.4% on wages once uncapped SDI is counted), the country’s highest state gas taxes, and a budget process that reached for roughly $2 billion in new annual revenue this cycle alone.

6

SB 122’s sourcing rule makes your address the deciding factor

The statute sources electronically delivered and remotely accessed software to the purchaser’s address. A subscription billed to a California address is taxed. The same subscription billed to a Florida address is not, because Florida treats electronically delivered software as a nontaxable intangible.

7

Florida’s advantage is structural, not a marketing pitch

Florida’s constitution prohibits a personal income tax, and the Department of Revenue has held for years (TAA 16A-014) that electronically delivered software and SaaS are not subject to sales tax. Florida is not free: sales tax on goods runs about 6–8% and property insurance is genuinely expensive. But the income-tax ban cannot be undone by a June budget deal.

8

Leaving wrong is worse than staying

The Franchise Tax Board audits departures aggressively. A move that is real on paper but thin in fact (no lease, no license change, no severed ties) invites a residency audit that can keep you a California taxpayer years after you think you left. Domicile has to be documented, not just declared.

9

The window before January 1, 2027 matters

Domicile established and documented before the new taxes take effect means 2027 income, software purchases, and premiums are sourced to your new state from day one, and your final part-year California return starts the statute-of-limitations clock.

This article is part of our State Tax Migration Guide series. See also: California to Florida Residency

Read this first: This article is for educational purposes only and does not constitute tax, legal, or financial advice. Consult a qualified tax professional or attorney before making domicile or residency decisions. Both laws discussed here were signed June 29, 2026; SB 125 still requires federal approval before collection, and implementing guidance from the CDTFA is expected before the January 1, 2027 effective date.

Maya runs a one-person design studio out of a rented apartment in Long Beach. Her software stack (design suite, prototyping tool, cloud storage, accounting app, e-signature service) costs her about $4,100 a year, every dollar of it deductible, none of it taxed. On January 1, 2027, that changes: California will treat every one of those subscriptions as taxable tangible personal property, at Long Beach's combined sales tax rate, billed to her Long Beach address.

Her health plan is changing too. The same June budget that created the software tax also rebuilt the state's tax on managed care plans, and the independent Legislative Analyst's Office expects insurers to pass a meaningful share of it into premiums.

Neither tax will bankrupt Maya. Combined, they might cost her $450 a year. That is precisely what makes them worth understanding, because the question they raise is not "can I afford $450?" It is "what does it mean that the state found two brand-new things to tax this year, and what stops it from finding two more next June?"

This guide covers the new California taxes taking effect in 2027 in full:

  • What SB 122 (the digital software sales tax) actually taxes, and the exclusions most headlines get wrong
  • What SB 125 (the health plan tax) means for your premium, with the honest caveats
  • What the two taxes cost real households and freelancers, in dollars
  • Why the sourcing rule buried in SB 122 makes your address the deciding factor
  • An honest look at whether Florida is actually greener, including where it isn't
  • The before-January-1 checklist if you decide the trajectory is the answer

Free Tool

See what California costs you at your exact income

The two new taxes are the tip. Compare your total California tax burden against Florida's side by side: income tax, the new software tax treatment, and what changes the day your domicile does.

Run the comparison →

What Sacramento signed on June 29, 2026

Governor Newsom signed the 2026–27 state budget on June 29, 2026, closing a multibillion-dollar shortfall in part with two revenue measures that were chaptered the same day:

The taxWhat it doesEffectiveProjected revenue
SB 122: digital software sales taxExtends sales & use tax to prewritten software and SaaS, however deliveredJanuary 1, 2027~$900M/yr state + ~$1.1B/yr local, fully phased in
SB 125: MCO health plan tax$8.85 per enrollee per month on health plans, public and private, funding Medi-CalJanuary 1, 2027 (pending federal approval), for 2027–2029~$1.5B/yr from private plans; ~$2.3B/yr total

A California Taxpayers Association spokesperson described the package as the largest tax increase in state history from a dollar standpoint. That is a nominal-dollar claim worth quoting precisely, because it compares raw dollars rather than inflation-adjusted burden. The hard numbers behind it are not in dispute: CalTax president Robert Gutierrez put the proposals at $3.6 billion in annual tax increases, growing to $5.1 billion in 2027–28, warning they "will hurt every industry in the state and cause higher costs for all consumers."

Let's take the two taxes one at a time, precisely.

Tax #1. SB 122: California starts taxing software and SaaS

Since the dawn of the download, California has taxed software only when it arrived on a disc. SB 122 ends that. Effective January 1, 2027, the law expands the definition of taxable "tangible personal property" to include digital products, defined as prewritten computer software "transferred on tangible storage media, transferred electronically, or accessed remotely."

In plain English: the same sales tax you pay on a laptop now applies to the software running on it. The statewide base rate is 7.25%; combined rates with local district taxes commonly run 8.5% to 10.75% depending on the city.

What's taxed, and what escaped

The exclusions are where most of the reporting has gone wrong, so here is the actual line the statute draws:

▸ TAXED starting January 1, 2027 (tap to expand)
  • SaaS subscriptions: design suites, office and productivity software, project management, CRM, accounting tools
  • Downloaded prewritten software: tax-prep desktop editions, antivirus, creative applications
  • Remotely accessed software: cloud tools you never install at all
  • Physical-media software: already taxable, stays taxable
▸ NOT taxed: the exclusions the headlines miss (tap to expand)
  • Streaming video and music: audiovisual and audio works are excluded, so Netflix and Spotify are out
  • Video games: explicitly excluded
  • Ebooks and digital books: excluded
  • Visual works and digital assets: excluded
  • Custom software: software built to a single customer's specification remains exempt, as it always was

Notice the shape of that line. Entertainment escaped; the working stack did not. The tax lands on the tools people use to earn a living. That is why the Legislative Analyst's Office flagged that a substantial share of the taxable base is business-to-business, and why its own analysis warns that taxes on business inputs "can lead to inefficient business operations and higher costs," with businesses typically passing those costs into consumer prices.

The sourcing rule is the tell

Buried in SB 122 is the provision that matters most for anyone reading this article: electronically transferred or remotely accessed software is sourced to the purchaser's address. That is how the CDTFA will know which district rate to charge, and whether to charge California tax at all.

Why this matters: The same $60/month subscription is a taxable California sale when billed to a Long Beach address and a nontaxable transaction when billed to a genuine Florida address, because Florida's Department of Revenue has held for a decade (Technical Assistance Advisement 16A-014) that electronically delivered software and SaaS are not tangible personal property and are not subject to sales tax. The tax follows the address. So does the exemption.

What SB 122 costs at real subscription prices

Illustrative numbers for a self-employed professional's stack, at a 9.75% combined big-city rate (statewide base is 7.25%; some districts exceed 10%):

Subscription (illustrative)Annual spendNew CA tax @ 9.75%Tax if billed to a Florida address
Creative/design suite ($60/mo)$720$70$0
Office/productivity bundle$130$13$0
Tax-prep desktop download$80$8$0
Cloud storage + backup$220$21$0
Business tools (CRM, e-sign, accounting)$2,950$288$0
Total stack$4,100~$400/yr$0

A casual household with a couple of subscriptions might see $50–$120 a year. A freelancer or consultant running a serious stack: $300–$600. A small agency paying for ten seats of everything: thousands, before the pass-through effects on everything else they buy.

Tax #2. SB 125: the health plan tax heading for your premium

The second tax is quieter and larger. California has long taxed managed care organizations (MCOs) to help fund Medi-Cal, but it taxed Medi-Cal plans at a far higher rate than commercial plans. A federal Centers for Medicare and Medicaid Services final rule banned that structure this year. SB 125 (Chapter 24, Statutes of 2026) is the redesign: every plan, public and private, pays the same $8.85 per countable enrollee per month for calendar years 2027 through 2029.

The arithmetic that matters to you:

  • ~$1.5 billion a year is the expected new burden on private plans (about $2.3 billion total, restoring what the state collected before 2023).
  • ~1.5% premium increase is the Legislative Analyst's Office estimate if plans pass the full tax through: roughly $100 a year for an individual, $400 for a family of four.
  • Federal approval is required. The Department of Health Care Services cannot collect until CMS certifies the tax as federally permissible. Collection begins January 1, 2027 or upon approval, whichever is later, and the tax sunsets January 1, 2031.
  • Revenue flows to a new Medi-Cal Stability Fund for capitation payments and reimbursement rates.

Be realistic: nothing in SB 125 forces insurers to pass the tax to you, and nothing stops them. Treat the $100/$400 figures as the LAO's central estimate of pass-through, not a line item you will see on a bill. What is certain is the direction: a $1.5 billion annual cost added to the private insurance market does not make premiums cheaper.

What the two taxes cost a real household (and why that's not the real number)

ProfileSB 122 software taxSB 125 premium impactNew taxes, total/yrCA income tax they already pay*
Single, light subscriber, $85K~$60~$100~$160~$4,300
Freelancer with a full stack, $150K~$400~$100~$500~$10,800
Family of four, two incomes, $250K~$150~$400~$550~$19,700
Tech professional, $400K~$250~$400~$650~$36,000+

*Approximate California income tax, single/joint filers with standard assumptions; your figures will differ. Run your own numbers below.

Look at the last two columns together. That is the honest frame for the 2027 California tax increases: the two new taxes are a rounding error next to the income tax bill that a California address already generates. That bill runs to a top statutory rate of 13.3%, and effectively 14.4% on high wages once the now-uncapped State Disability Insurance levy is counted. The new taxes do not change the math. They confirm its direction.

$

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The pattern is the point. In the span of a few budget cycles, California has reached for a retroactive-feeling credit limitation on businesses, an exit-tax proposal that resurfaces every session, a wealth-tax bill that keeps returning, and now a brand-new consumption tax on the tools of modern work plus a health-plan tax expected to reach premiums. Each individual measure is defensible in Sacramento's terms. Together they describe a state whose structural budget gap (the Medi-Cal shortfall alone drove much of this year's deal) guarantees that next June's budget will go looking for revenue too. If you want a deeper look at that trajectory, see our analysis of why high earners are leaving California and what the recurring California exit tax proposals would mean if one finally passes.

BEFORE THE JANUARY 1, 2027 EFFECTIVE DATE

Sacramento Found Two New Things to Tax This Year. Your Address Is the Only Veto You Get.

SB 122 and SB 125 passed as budget trailer bills: no ballot, no vote, effective January 1, 2027. Both taxes follow your address, and so does California's 13.3% income tax. Your Tax Base gives you a genuine residential Florida address, the §222.17 Declaration of Domicile filing, and an audit-ready documentation file, so the taxes that follow an address stop following yours.

Is the grass actually greener? An honest Florida comparison

Here is where most articles like this one lose their credibility, so let's not. Florida is not a tax-free paradise where everything costs less. It is a state with a different structure, and for taxes specifically, the structure is the whole story.

California (2027)Florida (2027)
Personal income tax1%–13.3% (up to 14.4% on wages with SDI)0%, prohibited by the state constitution
SaaS & downloaded softwareTaxable from Jan 1, 2027 (SB 122), 7.25%+ localNot taxable (FL DOR, TAA 16A-014)
Sales tax on goods7.25% base; commonly 8.5%–10.75% combined6% base; commonly 6%–8% combined. Real, not zero
Capital gainsTaxed as ordinary income, up to 13.3%0% state tax
Estate/inheritance taxNone (but recurring wealth-tax proposals)None, constitutionally limited
Property insuranceRising; wildfire-market stressGenuinely expensive; hurricane-market stress. Budget for it
How taxes changeSimple majority budget deal, most JunesIncome-tax ban requires amending the constitution

Two rows in that table do the real work.

First, the software row: the exact thing California just started taxing is a thing Florida has formally declined to tax. The Florida Department of Revenue's long-standing position (Technical Assistance Advisement 16A-014) is that electronically delivered software, SaaS subscriptions, and cloud services are intangibles outside the sales tax entirely. This is not a loophole; it is the published policy.

Second, the last row. California's new taxes arrived through an ordinary June budget agreement, as next year's can. Florida's 0% income tax is not a legislative preference that could evaporate; it is a constitutional prohibition, changeable only by amending the constitution itself. When people say the grass is greener in Florida, this is the part that is actually true. It is not that Florida is cheap (its insurance market will remind you it is not), but that its tax structure is stable by design. You are not trading one legislature's appetites for another's. You are exiting the category of resident whose income can be reached at all.

For the fuller state-by-state picture, including states that look tax-friendly but claw at departing residents, see our 50-state tax residency rules guide and the State Tax Migration Guide pillar.

The address is the only veto you have

You cannot vote down SB 122 or SB 125; both passed as budget trailer bills, no ballot required. The one variable in every one of these statutes that you control is the address the tax sources to. SB 122 says so explicitly: the tax follows the purchaser's address. The income tax says it structurally: California taxes the worldwide income of California domiciliaries. Change the domicile, and 2027's new taxes (and the old ones) stop sourcing to you.

But domicile is a legal fact, not a mailing preference, and this is where people get hurt. The Franchise Tax Board audits departures aggressively, and it wins against moves that were real on paper and thin in fact. A genuine change of domicile from California to Florida means:

  • A real residential address: a lease or deed at a residential-class Florida address, not a PO box or commercial mail drop. Banks, the DMV, and auditors all check the address class; a mail-drop address is the single fastest way to lose a residency audit.
  • The document trail: Florida driver license within 30 days (Florida Statutes §322.031), voter registration (§97.041), a recorded Declaration of Domicile (§222.17), IRS Form 8822 updating your federal address.
  • Severed California ties: final part-year return filed (it starts the statute-of-limitations clock), memberships closed, professional relationships moved, day counts logged.

Step-by-step instructions live in our dedicated guides: how to leave California residency, terminating California residency without triggering an FTB audit, how to become a Florida resident, and the complete Florida domicile checklist. If an auditor ever asks you to prove it, these are the five factors they will weigh.

The January 1 Countdown

Domiciled in Florida before the new taxes switch on

Your Tax Base provides the piece Californians can't improvise from abroad or mid-move: a genuine residential-class Florida address with a lease and utility record, plus the Declaration of Domicile filing path, mail service, and the audit-ready documentation file. When January 1, 2027 arrives, every tax that follows an address is following one that isn't yours anymore.

See the California-to-Florida residency service →

Your before-January-1 checklist

If you decide the trajectory is the answer, here is the sequence. Work it top to bottom; the order matters because each step becomes evidence for the next.

  1. Run the numbers first (July–August 2026). Use the state tax comparison tool to quantify what a Florida domicile changes at your income. The decision should be made on the income tax, with the new 2027 taxes as confirmation.
  2. Secure a residential-class Florida address (August–September). Lease or deed, residential USPS classification, utilities in your name. This is the foundation every later document points back to.
  3. Make the physical move and start the log. Presence plus intent is the legal test; a contemporaneous travel log reconciled to card statements is the evidence.
  4. Convert the paperwork inside 30 days (October). Florida driver license (§322.031, surrender the California license), voter registration, vehicle registration.
  5. Record your Declaration of Domicile (§222.17). Roughly a $10 county clerk filing that timestamps your intent. It is the single clearest signal available.
  6. Repoint every institution (November). Banks, brokerage, employer payroll, insurers, IRS Form 8822. Payroll matters most: California-sourced wages follow the work, but a Florida domicile stops California from taxing your worldwide income.
  7. Sever the residual California ties (December). Gym and club memberships, storage units, professional licenses you no longer need, the dentist. Auditors read ties like a jury reads motive.
  8. File the final part-year California return (spring 2027). It closes the chapter and starts the audit statute of limitations running. Skipping it leaves the window open indefinitely.
  9. Keep the file. Every document above goes in one place. If the FTB ever asks, you answer in an afternoon. That is what audit-proof means.

Frequently asked questions

What are California's two new taxes for 2027?

SB 122 extends sales and use tax to digital prewritten software and SaaS effective January 1, 2027, and SB 125 rebuilds the MCO health plan tax at $8.85 per enrollee per month for 2027–2029. Both were signed June 29, 2026 with the state budget and together are projected to raise roughly $2 billion a year once fully phased in.

Does the software tax apply to individuals or just businesses?

Both. Consumer subscriptions are covered directly, and the LAO expects the large business-to-business share to reach consumers anyway through prices.

Are Netflix, Spotify, or video games taxed under SB 122?

No. Audio, audiovisual works, video games, books, visual works, and digital assets are explicitly excluded. The tax targets prewritten software: SaaS, downloads, and remotely accessed tools.

How much will SB 125 raise my health insurance premium?

If fully passed through (the LAO's working assumption), roughly 1.5%: about $100 a year for an individual and $400 for a family of four. Collection also requires federal CMS approval first.

Can moving out of California really avoid the software tax?

Yes. SB 122 sources electronically delivered and remotely accessed software to the purchaser's address, and Florida does not tax electronically delivered software at all (TAA 16A-014). The address must be your genuine domicile, consistently on file, not a mail drop.

Is this really the largest tax increase in California history?

That is a California Taxpayers Association characterization ("from a dollar standpoint," per a CalTax spokesperson), meaning nominal dollars, not inflation-adjusted. The undisputed figures: $3.6 billion in annual increases proposed, growing to $5.1 billion in 2027–28.

Do I have to move before January 1, 2027?

No, but a domicile completed in 2026 means the new taxes never source to you, your 2027 income is not California income from day one, and your final part-year return covers 2026 cleanly. A mid-2027 move splits the tax year instead.

Does Florida tax SaaS or downloaded software?

No. The Florida Department of Revenue treats electronically delivered software and cloud services as nontaxable intangibles. Only software delivered on physical media is taxable.

Will California audit me if I move?

It might; the FTB audits departures aggressively, especially around liquidity events. Audits are won with documentation: real address, converted licenses, recorded Declaration of Domicile, severed ties, day counts. See our domicile audit guide.

What does it take to change domicile from California to Florida?

Physical presence plus demonstrated intent: a genuine residential address, Florida driver license within 30 days, voter registration, a §222.17 Declaration of Domicile, updated federal and financial records, and a final part-year California return. A domicile service like Your Tax Base manages the address and the documentation file end to end.

Sacramento writes a new tax bill every June. Write yourself out of the mailing list.

Your Tax Base gives Californians a genuine residential Florida address, the Declaration of Domicile filing, mail service, and an audit-ready documentation file: the full legal foundation for 0% state income tax, in place before the 2027 taxes switch on.

Start Your Florida Domicile →

Or book a consultation to talk through your exit timeline first.

Related guides

Leaving California

Establishing Florida domicile

Residency rules & audits

Authority references cited in this guide

Important Disclaimer

This article is for educational purposes only and does not constitute tax, legal, or financial advice. Figures reflect the law as of July 2026; SB 125 requires federal approval before collection, CDTFA implementing guidance for SB 122 is pending, and premium pass-through estimates are Legislative Analyst's Office projections, not guarantees. State tax laws change frequently. Consult a qualified tax professional or attorney before making domicile or residency decisions. Your Tax Base provides domicile establishment services but is not a law firm, CPA firm, or registered tax advisory service. Our services do not constitute legal or tax advice.

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