Kroll Tax Insights Q2 2026

Organizations with multistate operations may be overpaying sales tax on software licenses due to vendor reliance on billing-location taxation rather than actual usage. The article explains how the multiple points of use (MPU) rule enables companies to allocate software costs based on user location, often unlocking significant refund opportunities across a three-to-four-year lookback period. For enterprises with distributed workforces and substantial software spend, MPU reviews can yield multimillion-dollar recoveries while establishing more accurate prospective tax treatment.

Following the invalidation of International Emergency Economic Powers Act tariffs, the U.S. administration is using Sections 232 and 301 to sustain and expand its trade policy agenda. New Section 301 investigations targeting excess capacity and forced labor, combined with significant modifications to Section 232 tariffs on metals and derivatives, are creating a more complex and dynamic trade environment. The resulting framework introduces greater uncertainty but also signals a shift toward more durable, statute-based tariff enforcement with implications for sourcing, compliance and supply chain strategy.

In high-stakes property acquisitions, tax planning has become integral to due diligence and valuation. The article outlines how property tax considerations—including reassessment risk, historical compliance and asset classification—directly impact net operating income and deal economics. Proactive tax analysis enables buyers to identify hidden liabilities, negotiate favorable terms and safeguard long-term returns in increasingly complex transactions.