Carnê-Leão for Remote Workers & Digital Nomads in Brazil

You took the digital-nomad visa, or you simply kept your overseas job and moved to Brazil. The salary still lands in a foreign account, paid by a company that has never heard of the Receita Federal. So the natural assumption is that Brazil has nothing to do with it — or that, if it does, the tax will somehow be handled when you file once a year. Then someone mentions Carnê-Leão, and the comfortable picture cracks.

Here is the pivot the whole guide turns on: for foreign-source and individual-source income, Brazilian income tax is not annual and it is not withheld for you — it is monthly, and you assess and pay it yourself. That is what Carnê-Leão is. If you are a Brazilian tax resident earning a foreign salary or freelancing for clients abroad, you owe a payment every month the money arrives, due by the last business day of the following month — not a single reconciliation in April.

The good news is that the system is mechanical once you understand it: a monthly table, a currency conversion rule, a government tool that does the arithmetic, and a single revenue code. The risk is that it is easy to miss for a full year without realising it, and the penalties compound month by month.

This guide is educational content prepared by the ZS Advogados team for remote workers, freelancers, and digital nomads — people on a VITEM XIV digital-nomad visa, or simply living in Brazil while earning abroad — and for the accountants and partners helping them get compliant. It pairs with our companion guides on remote work in Brazil for a foreign employer, income tax for foreigners in Brazil, and the Brazil digital-nomad visa. It explains what Carnê-Leão is, exactly who owes it, how to calculate and pay it, and how the digital-nomad and foreign-employer nuances actually work.

What is Carnê-Leão, and why is it monthly?

Carnê-Leão is the monthly self-assessment of Brazilian individual income tax (IRPF) on income that arrives without a Brazilian paying source to withhold it for you. The Receita Federal defines it precisely: it is the income tax on the monthly income of an individual resident in Brazil received from another individual or from abroad (recebida de outra pessoa física ou do exterior).

That definition is the key to the whole thing. When a Brazilian company pays you a salary, it withholds income tax at source (IRRF) and hands it to the government on your behalf — you do nothing month to month. But when the payer is a foreign company, or an individual (a private tenant, a freelance client who is a natural person), there is no Brazilian withholding agent in the chain. Brazil’s answer is to shift the duty onto you: you self-assess the tax each month and pay it yourself. That self-assessment is Carnê-Leão.

For a remote worker or digital nomad this is exactly the income that matters: a salary from an employer abroad, fees from foreign clients, a foreign pension, rent from property abroad. None of it is touched by a Brazilian payroll, so all of it lands in the Carnê-Leão net once you are a tax resident.

Two features make Carnê-Leão different from the annual return and easy to overlook. First, it is monthly — a fresh obligation every month income arrives, not a once-a-year event. Second, it is self-assessed — nobody sends you a bill; you are expected to know you owe it, calculate it, and pay it. The amounts you pay each month are then consolidated into your annual DIRPF, where withholding, credits, and the final reconciliation happen.

Legal basis: Carnê-Leão — the monthly income tax on income received by a Brazilian resident from individuals or from abroad — is set out in Receita Federal’s Carnê-Leão guidance (gov.br/receitafederal) and consolidated in the annual DIRPF. The underlying obligation sits in the income-tax regulation (RIR/2018) and the IRPF legislation.

Who actually owes Carnê-Leão — and does the digital-nomad visa matter?

Carnê-Leão is owed by Brazilian tax residents. That phrase does the heavy lifting, because tax residency — not your visa, not your nationality — is what switches the obligation on.

Under Normative Instruction SRF nº 208/2002, the main residency triggers are:

• On arrival, with permanent status. Someone who enters Brazil with a permanent visa or permanent-residence authorization is a tax resident from the day of arrival, with no waiting period.
• After 184 days, on a temporary basis. Someone in Brazil on a temporary footing — and this is the common situation for a digital nomad — becomes a tax resident once they complete 184 days, continuous or not, within any 12-month period.
• On return, for a Brazilian who had previously filed a saída definitiva and comes back.

Note that the 184-day count runs forward to the 184th day within a rolling 12-month window — it is not retroactive to your first entry, and it is not 183. A pattern of long stays can quietly cross the line even without a single continuous trip. For the full residency analysis, see our tax residency in Brazil guide.

Here is the part that surprises digital-nomad-visa holders most. The VITEM XIV digital-nomad visa governs immigration, not tax. It lets you live in Brazil while working remotely for a foreign employer; it says nothing about whether you owe Brazilian tax. The tax question is answered separately by IN SRF 208/2002. So a nomad on a VITEM XIV who stays past the 184-day mark generally becomes a Brazilian tax resident — and from that point the foreign salary they earn remotely is in the Brazilian system, with the monthly slice captured by Carnê-Leão. The visa neither triggers nor exempts the tax; the day-count does. See our guide on taxes for digital nomads in Brazil for the residency-and-visa interaction in full.

Legal basis: entry with permanent status, the 184-day rule within a 12-month window, and the return-of-an-exited-Brazilian rule are set out in IN SRF 208/2002, art. 2. The digital-nomad visa (VITEM XIV) is an immigration category and does not alter these tax-residency criteria.

Speak to counsel — when did residency start? The exact date your tax residency begins is fact-specific (visa type, day-count, intent, prior exit filings) and it sets the first month Carnê-Leão is due. Get the residency-start date analysed against your real dates before back-calculating months of liability.

How do I calculate Carnê-Leão? The 2026 monthly table

The calculation has three moving parts: convert the income to reais, apply the monthly progressive table, and subtract any allowable deductions.

The 2026 monthly progressive table runs as follows:

Monthly base (R$)	Rate	Deduction (parcela a deduzir, R$)
Up to 2,428.80	0% (exempt)	—
2,428.81 – 2,826.65	7.5%	182.16
2,826.66 – 3,751.05	15%	394.16
3,751.06 – 4,664.68	22.5%	675.49
Above 4,664.68	27.5%	908.73

You apply the rate for the band your monthly income falls into and subtract the corresponding deduction to get the tax due that month. The same brackets and 27.5% ceiling that govern salaried Brazilians apply here — Carnê-Leão is not a separate, harsher regime; it is the ordinary IRPF table assessed monthly by you instead of withheld by a payer.

On top of this base table, a 2026 reform overlay provides extra relief at the bottom: an additional reduction that effectively zeroes IRPF for monthly income up to roughly R$5,000, then tapers off up to about R$7,350, above which the full table applies. The relief is calculated by a formula the official table and tool apply automatically.

Speak to counsel — confirm the relief band. The 2026 reform tables and the exact low-income relief band were still being finalised at the time of writing. Treat the up-to-R$5,000 exemption and the R$7,350 taper as the working framework, and confirm the precise figures and formula against the official Receita Federal table before relying on a specific number.

Legal basis: the monthly progressive table, exemption ceiling, and per-bracket deductions are published by Receita Federal in the annual income-tax tables (2026); the low-income relief overlay sits on top of that base table under the 2026 IRPF reform.

How do I convert foreign income — the PTAX rule

Because a remote worker’s income usually arrives in dollars, euros, or pounds, the conversion step is not optional and it is not done at “today’s rate.” Brazil prescribes a specific reference rate.

The rule: if you were paid in a currency other than the US dollar, first convert to US dollars, then convert the dollars to reais using the Banco Central PTAX buy rate (dólar de compra). The reference date is the PTAX buy rate from the last business day of the first fortnight (primeira quinzena) of the month before the month you received the income.

In practice that means a fixed lookup. For income received in March, you generally use the PTAX buy rate from on or around 15 February (the last business day of the first half of February). The “Meu Imposto de Renda — Carnê-Leão” tool applies the conversion for you when you enter the receipt date and the foreign amount, but it helps to understand which rate it is pulling, because it is not the spot rate on the day you were paid.

Legal basis: foreign income is converted to reais at the Banco Central PTAX buy rate of the last business day of the first fortnight of the month prior to receipt — the standard Receita Federal rule for foreign-source income reflected in the Carnê-Leão tool and the IRPF manual; PTAX is published by the Banco Central do Brasil.

What can I deduct — the livro-caixa

Carnê-Leão is not always charged on the gross amount. There are two layers of deduction.

First, the standard personal deductions the IRPF allows on a monthly basis — dependants, qualifying alimony/pension payments, official social-security contributions — reduce the base before the table is applied.

Second, and important for self-employed and professional income, the livro-caixa (cash book) lets you deduct legitimate, documented business expenses incurred to earn the income. Typical livro-caixa items include rent and upkeep of a professional space, utilities and services tied to the activity, and certain supplies and equipment costs. The livro-caixa deduction lowers the monthly Carnê-Leão base for autonomous and professional work — a freelancer’s deductible costs come off before the table is applied.

A crucial limit: the livro-caixa applies to self-employed/professional income, not to ordinary employment-type salary. A remote worker who is, in substance, an employee of a foreign company generally cannot use the livro-caixa against that salary; a genuine freelancer/professional billing foreign clients generally can, for the costs of that activity. Which side of the line your arrangement falls on is fact-specific and consequential.

Speak to counsel — employee or self-employed? Whether your remote arrangement is employment income or genuine self-employed/professional income determines both the livro-caixa eligibility and other treatment. Foreign “contractor” labels do not automatically mean self-employed under Brazilian analysis. Have the substance of your arrangement reviewed before claiming livro-caixa deductions.

Legal basis: the livro-caixa deduction for self-employed/professional income, and the standard personal deductions, are set out in Receita Federal’s Carnê-Leão “Deduções” guidance and the IRPF regulation (RIR/2018).

How do I actually pay it — the tool, the DARF, and the deadline

The mechanics, end to end, are deliberately self-service.

1. Open the tool. Use “Meu Imposto de Renda — Carnê-Leão” — available online and in the gov.br app — which has replaced the old standalone Carnê-Leão program. It is where you enter income, deductions, and conversions, and it carries the data forward into your annual return.
2. Enter the month’s income and deductions. Record each receipt with its date, source, and amount (foreign amounts are converted at the PTAX rule above), plus dependants, livro-caixa expenses, and other allowable deductions.
3. Generate the DARF. The tool calculates the tax and issues a DARF (the federal payment slip). The Carnê-Leão revenue code is 0561 — this is the code that appears on the DARF.
4. Pay by the deadline. The DARF is due by the last business day of the month following the month of receipt. Income received in March → pay by the last business day of April; income received in April → pay by the last business day of May, and so on.
5. Import into the DIRPF. When you file the annual return, the Carnê-Leão data imports automatically, and the monthly payments are credited against the annual tax in the final reconciliation.

Step	What it is
Tool	”Meu Imposto de Renda — Carnê-Leão” (web + gov.br app)
Payment slip	DARF, revenue code 0561
Deadline	Last business day of the month after receipt
Conversion	PTAX buy rate, last business day of prior month’s first fortnight
Year-end	Auto-imports into the annual DIRPF

Legal basis: the “Meu Imposto de Renda — Carnê-Leão” tool, DARF revenue code 0561, the last-business-day-of-the-following-month deadline, and consolidation into the annual DIRPF are all set out in Receita Federal’s Carnê-Leão guidance (gov.br/receitafederal). Verify the current code and deadline on the official page before paying.

What are the penalties for paying late or missing it?

This is where the monthly nature of Carnê-Leão bites, because a single overlooked obligation can quietly become twelve.

There are two distinct penalty paths, and which one applies depends on whether you fix it before filing the annual return.

• You pay late, but before your annual DIRPF. You generally owe the tax plus the multa de mora — a late-payment fine of 0.33% per day, running from the first business day after the due date and capped at 20% — plus Selic interest accrued over the delay. This is the ordinary, cheaper cleanup path.
• You never pay and Receita Federal assesses it (lançamento de ofício). An isolated fine (multa isolada) of 50% of the unpaid monthly amount applies, under Lei nº 9.430/1996, art. 44, II, “a”. This 50% isolated fine is charged for the failure to pay the monthly Carnê-Leão itself — and case law treats it as separate from any penalty for omitting the same income in the annual adjustment, because they are distinct infractions. In other words, do not assume that “I’ll just declare it all in April” neutralises the monthly default.

The practical takeaway: the difference between the cheap path and the expensive path is whether you regularise before the annual return. Paying late voluntarily, before filing, keeps you on the multa-de-mora track. Letting it sit until Receita assesses opens the 50% isolated fine.

Speak to counsel — quantify your exposure. The interaction between the 50% isolated fine, the 75% official fine on omitted income, multa de mora, and Selic is fact-specific, and there is litigation on concurrency. If you have unpaid months, have the exposure quantified and a regularisation route mapped before you act — do not self-assess penalties from an online summary.

Legal basis: the multa de mora of 0.33% per day capped at 20% plus Selic interest is the standard federal late-payment rule; the 50% isolated fine for failure to pay monthly Carnê-Leão is Lei nº 9.430/1996, art. 44, II, “a” (as amended by Lei nº 11.488/2007).

How does Carnê-Leão fit into the annual DIRPF?

Carnê-Leão is not a separate tax — it is a prepayment mechanism for the IRPF you will reconcile annually. Think of it as the foreign-income equivalent of payroll withholding.

Every month you self-assess and pay through the tool. At year-end, when you file the DIRPF (the annual individual return — filed in 2026 for base year 2025, and in 2027 for base year 2026), the Carnê-Leão data imports automatically into the return. The income flows into your total taxable income, and the monthly payments you made are credited against the total IRPF due. If you overpaid across the year you may be in refund; if you underpaid, the balance is settled in the annual return.

For a remote worker this means two things. First, you should still file the annual DIRPF even though you paid monthly — Carnê-Leão does not replace the return, it feeds it. Second, if there is foreign tax on the same income and a relief mechanism applies, the credit is claimed in the DIRPF, not in the monthly Carnê-Leão. (Brazil has no comprehensive income-tax treaty with the United States as of June 2026; US-source income relief runs through reciprocity, claimed annually — see our guide on US taxes while living in Brazil with no treaty.)

You also list your assets — including foreign accounts — in the DIRPF’s “Bens e Direitos” section, and if foreign assets cross the Banco Central CBE threshold, that is a separate filing again. See declaring foreign assets in Brazil.

Legal basis: Carnê-Leão payments are advances of the annual IRPF, consolidated and credited in the DIRPF; the DIRPF filing obligation, income consolidation, and crediting of prepaid Carnê-Leão are set out in Receita Federal’s annual income-tax guidance (gov.br/receitafederal).

Is a foreign salary Carnê-Leão, or is it taxed some other way?

This is the question most remote workers actually have, so it deserves a direct answer.

When you are a Brazilian tax resident and a foreign employer pays you directly, with no Brazilian paying source in the chain, there is no Brazilian withholding (IRRF) — nobody in Brazil is positioned to withhold. That is precisely the situation Carnê-Leão exists for: the foreign salary becomes your monthly self-assessment. It is not “taxed automatically,” and it is not deferred to the annual return; it is your duty to assess and pay it each month under DARF 0561.

Contrast the alternatives so the boundary is clear:

• Foreign employer, paid abroad, no Brazilian source → Carnê-Leão (monthly self-assessment). The typical remote-worker case.
• Brazilian source pays you (e.g. a Brazilian employer or, in some structures, a Brazilian entity) → withholding at source (IRRF), handled by the payer.
• Income from individuals in Brazil (private tenant, freelance client who is a natural person) → Carnê-Leão, same monthly mechanism.

There is also a structural choice some remote workers consider — invoicing through a Brazilian company (PJ) under a regime such as Simples Nacional instead of receiving as an individual (PF). That changes the tax mechanism entirely (corporate-level taxes instead of Carnê-Leão) and has trade-offs around cost, labour-law exposure, and the foreign client’s willingness to contract with a company. It is a planning decision, not a default. See our comparison-style guide on remote work in Brazil for a foreign employer.

Speak to counsel — PF vs PJ is a real decision. Whether to receive foreign income as an individual (Carnê-Leão) or through a Brazilian company is a structuring question with tax, labour, and commercial consequences. There is no one-size answer; it depends on income level, activity, and the foreign payer. Have it modelled on your numbers before choosing.

Legal basis: the absence of Brazilian withholding on foreign-source income paid by a foreign employer — and the resulting Carnê-Leão obligation — follows from Receita Federal’s Carnê-Leão definition (income “from abroad”) and the IRRF rules that apply only where a Brazilian source pays; PF-vs-PJ treatment follows the respective IRPF and corporate-tax regimes.

Hypothetical illustration — not a real client.

Imagine a software developer who keeps her job at a US startup, takes Brazil’s digital-nomad visa, and settles in Florianópolis. Her salary — US$8,000 a month — lands in her US bank account, paid by the US company, with no Brazilian payroll involved.

For her first months on a temporary footing she is not yet a Brazilian tax resident. Once she crosses 184 days within the 12-month window (IN SRF 208/2002), she becomes one. From the month residency starts, her US salary falls under Carnê-Leão: each month she opens “Meu Imposto de Renda — Carnê-Leão,” converts the US$8,000 at the PTAX buy rate from the last business day of the first fortnight of the prior month, applies the monthly table (her income is well above the R$4,664.68 band, so the marginal 27.5% applies, less the deduction), generates the DARF under code 0561, and pays by the last business day of the next month. Because she is an employee in substance, she does not use the livro-caixa against the salary. At year-end the monthly data imports into her DIRPF, where she lists her US accounts in “Bens e Direitos” and claims any US-tax relief by reciprocity (no US treaty). On the US side she keeps her own US tax adviser for FBAR/FATCA, which Brazilian counsel does not handle.

Every distinguishing detail here is invented. Real situations turn on their own facts, dates, currencies, and documents, and require individual analysis. Nothing in this example predicts any outcome.

What are the most common mistakes?

The errors cluster around one root confusion — treating foreign income as “someone else’s problem” or as an annual event.

• Assuming the foreign salary is invisible to Brazil. Once you are a tax resident, income “from abroad” is squarely within Carnê-Leão. The foreign employer’s ignorance of Brazil changes nothing.
• Waiting for the annual return. Carnê-Leão is monthly. Paying it all in April does not cure the monthly defaults and can expose you to the 50% isolated fine.
• Thinking the digital-nomad visa exempts you. The VITEM XIV is an immigration status. Tax residency — and the 184-day count — is a separate test under IN SRF 208/2002.
• Converting at the wrong rate. It is the PTAX buy rate from the last business day of the prior month’s first fortnight, not the spot rate on payday.
• Using the livro-caixa against salary. The cash-book deduction is for self-employed/professional income, not for employment-type salary.
• Missing the DARF code. Carnê-Leão pays under code 0561; paying under the wrong code creates reconciliation headaches.
• Counting 184 days backward, or using 183. The count runs forward to the 184th day within a rolling 12-month window.
• Treating US obligations as Brazilian counsel’s job. FBAR, FATCA, and US worldwide tax are US-law matters that require a US tax professional.

Carnê-Leão at a glance

Item	Detail
What	Monthly self-assessment of IRPF on income from individuals or from abroad
Who	Brazilian tax residents (IN SRF 208/2002) — incl. nomads past the 184-day line
2026 table	Exempt to R$2,428.80; 7.5% / 15% / 22.5% / 27.5%; low-income relief overlay
Conversion	PTAX buy rate, last business day of prior month’s first fortnight
Deductions	Standard personal deductions; livro-caixa for self-employed/professional
Tool	”Meu Imposto de Renda — Carnê-Leão” (web + gov.br app)
Payment	DARF, revenue code 0561
Deadline	Last business day of the month after receipt
Late (pre-DIRPF)	Multa de mora 0.33%/day, capped 20% + Selic
Unpaid (assessed)	Isolated fine 50% (Lei 9.430/1996, art. 44, II)
Year-end	Auto-imports and credits into the annual DIRPF

Key terms

• Carnê-Leão — the monthly IRPF self-assessment on income received from individuals or from abroad, consolidated in the annual return.
• DARF — Documento de Arrecadação de Receitas Federais; the federal payment slip. Carnê-Leão uses revenue code 0561.
• PTAX — the Banco Central reference exchange rate; foreign income is converted at the buy rate (compra) of the last business day of the prior month’s first fortnight.
• Livro-caixa — the cash book through which self-employed/professional taxpayers deduct documented business expenses.
• IRRF — Imposto de Renda Retido na Fonte; withholding at source — applies when a Brazilian source pays, and is what Carnê-Leão replaces when no such source exists.
• DIRPF — the annual individual income tax return, into which Carnê-Leão consolidates.
• Multa isolada — the 50% isolated fine for failure to pay monthly Carnê-Leão (Lei 9.430/1996, art. 44, II).
• Residência fiscal (tax residency) — the status that triggers worldwide-income taxation and the Carnê-Leão duty; defined by IN SRF 208/2002, independent of visa or citizenship.

Key takeaways

• Carnê-Leão is monthly and self-assessed — for foreign-source and individual-source income there is no Brazilian withholding, so the duty to calculate and pay falls on you, not on a payer.
• It is owed by Brazilian tax residents. The VITEM XIV digital-nomad visa does not exempt you; residency under IN SRF 208/2002 (184 days forward, or arrival with permanent status) is the trigger.
• The 2026 monthly table exempts income up to R$2,428.80 and rises to 27.5% above R$4,664.68, with a reform overlay zeroing tax up to about R$5,000 and tapering to about R$7,350 (confirm the relief band against the official table).
• Convert at the PTAX buy rate from the last business day of the prior month’s first fortnight — not the spot rate on payday.
• Self-employed/professional income can use the livro-caixa to deduct documented business expenses; ordinary salary cannot.
• Pay through “Meu Imposto de Renda — Carnê-Leão,” under DARF code 0561, by the last business day of the following month, and it auto-consolidates into the annual DIRPF.
• Penalties split on timing: late-but-before-the-return means multa de mora (0.33%/day, capped 20%) + Selic; never-paid-and-assessed means the 50% isolated fine (Lei 9.430/1996, art. 44, II).
• US-side rules (worldwide tax, FBAR, FATCA) are factual context only and sit outside Brazilian legal advice — retain a US tax professional.

Related guides on this site

• Remote work in Brazil for a foreign employer
• Income tax for foreigners in Brazil
• The Brazil digital-nomad visa: complete guide
• Brazilian tax residency and the exit tax
• Dual citizen Brazil tax & compliance checklist
• US taxes while living in Brazil with no treaty

How ZS Advogados can help

Remote-worker tax in Brazil turns on one pivot — the moment you become a tax resident — and the duty that flows from it is unusually unforgiving because it is monthly. A foreign salary that nobody withholds for you becomes your own obligation to convert, calculate, pay, and document twelve times a year, with penalties that compound if it is missed. The cleanest outcomes come from getting the residency date right and standing the monthly process up correctly from the first month, rather than reconstructing a year of defaults later.

Our team advises remote workers, freelancers, and digital nomads on the Brazilian side: pinning down the residency-start date, setting up the monthly Carnê-Leão routine under the correct table and PTAX rule, assessing livro-caixa eligibility, weighing the individual-versus-Brazilian-company (PF vs PJ) structuring choice, and coordinating the annual DIRPF and any reciprocity-based foreign-tax relief. We work in English and Portuguese, and every matter is built on the client’s actual facts, dates, and currencies.

• Tax law — Carnê-Leão set-up, IRPF/DIRPF compliance, PF-vs-PJ structuring, and foreign-income treatment
• Immigration and visas — digital-nomad (VITEM XIV) and residence status, and the residency date that triggers tax obligations
• International law — cross-border income, foreign-asset reporting, and reciprocity-based relief where no treaty exists

Book a consultation to have your specific residency and Carnê-Leão position reviewed before you act.

Technical review by the ZS Advogados Associados team, including co-founding partner Karina Peres Silvério (OAB/SP 331.050) and founding partner Zachariah Zagol (OAB/SP 351.356). Contact: contato@zsassociados.com — +55 (18) 3908-1653 — Presidente Prudente, SP.

Sources and legal basis

• Receita Federal — Carnê-Leão
• Receita Federal — Carnê-Leão: obrigatoriedade
• Receita Federal — Income tax tables 2026
• Receita Federal — orientação sobre a redução do IR a partir de 1º de janeiro de 2026
• Normative Instruction SRF nº 208/2002 — tax residency and worldwide income
• Lei nº 9.430/1996 — art. 44 (multas, including the isolated fine)
• Lei nº 11.488/2007 — amendments to art. 44 of Lei 9.430/1996
• Banco Central do Brasil — PTAX exchange rates
• PwC — Brazil: individual taxes on personal income
• PwC — Brazil: individual income determination

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This guide is for informational and educational purposes only, in line with Provimento No. 205/2021 of the Brazilian Bar Association (OAB). It is not legal advice, an opinion, or an offer of services, does not refer to any specific case, and does not guarantee any result. It describes Brazilian law and practice; references to United States tax rules (worldwide taxation, FBAR, FATCA) are factual context only and are not US tax advice — consult a qualified US tax professional. Rules and provisions are cited as of June 2026; changes after that date, including the pending 2026 IRPF reform relief tables, are not reflected. Each situation requires individual analysis by a licensed attorney. Last updated June 2026.