In this episode of the SALT Shaker Podcast, host and Eversheds Sutherland Associate Jeremy Gove rolls out a new discussion format—East/West/Middle. Joining Jeremy for this discussion are Partners Nikki Dobay and Breen Schiller, and Counsel Michael Hilkin, and the four discuss the similarities and differences of protesting an assessment in New York (East),

Breen Schiller

Illinois’ marketplace facilitator law – insights and analysis
Recent developments for Illinois’ marketplace facilitator tax law.
The latest
- October 1 – The Illinois Department of Revenue releases Sales and Use Tax Form CRT-63 “Sales Through Marketplace Facilitator Certificate.” (PDF). This certificate, which must be renewed annually, must be provided by marketplace facilitators to marketplace sellers. The certificate must be maintained with
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Michigan Court of Appeals reaffirms decision finding unconstitutional distortion
The Michigan Court of Appeals reaffirmed its March 2020 decision that application of the state’s statutory apportionment formula was unconstitutionally distortive as applied to a taxpayer’s Michigan Business Tax (MBT) liability. The Michigan Supreme Court vacated and remanded the Court of Appeals’ March 2020 decision, which was the topic of a prior SALT Shaker post…
Nexus news – recent Due Process and P.L. 86-272 cases
In this column for Journal of State Taxation, Eversheds Sutherland Partner Breen Schiller discusses two important nexus defenses, Due Process Clause and P.L. 86-272, as well developments in this area.
L is for local: Highlighting the evolution of local taxation, part II
On this episode of the Salt Shaker Podcast, host and Eversheds Sutherland Associate Jeremy Gove continues his discussion of local taxes with Partners Nikki Dobay and Breen Schiller. They expand on their prior discussion of municipal-level economic nexus provisions, the potential issues with their expansion and the potential legal issues regarding the attempt to…
L is for local: Highlighting the evolution of local taxation
On this episode of the SALT Shaker Podcast, host and Eversheds Sutherland Associate Jeremy Gove is joined by Partners Nikki Dobay and Breen Schiller to discuss the history and changing landscape of local taxation, and what that means for multistate taxpayers as well as small businesses.
During their conversation, they discuss the expansion of local…
It’s alive: the Illinois franchise tax and its impact on M&A
In this installment of A Pinch of SALT for Tax Notes State, Eversheds Sutherland attorneys Breen Schiller, Eric Tresh and Jeremy Gove explore the Illinois franchise tax and recommend that taxpayers reacquaint themselves with the mechanics of the tax to understand the potential pitfalls of various corporate transactions.
Buckeye State residency update: Ohio Department of Taxation finalizes residency rule
On August 17, 2021, the Ohio Department of Taxation finalized amendments to its rule governing the determination of resident status for personal income tax purposes. See our prior coverage of the draft (now finalized) rule here. The amendments are intended to modernize the factors to be considered – and to be disregarded – in…
Considerations and complexities of transactional nexus
In this episode of the SALT Shaker Podcast, host and Eversheds Sutherland Associate Jeremy Gove explores transactional nexus with Partner Breen Schiller. The two discuss the recent Quad Graphics, Inc. v. NC Department of Revenue decision out of North Carolina determining whether there was nexus to impose sales tax on out of state sales,…
Growing roots in the Palmetto State: South Carolina Department of Revenue issues guidance on domicile and residency
South Carolina’s Department of Revenue (DOR) recently published the inaugural edition of its Guide to Determining a Taxpayer’s Domicile for Income Tax Purposes (Guide). The publication issued by the DOR’s Policy Division provides a general overview of South Carolina’s domicile rules for income tax purposes. The intent of the guide is to assist taxpayers and…