In this episode of the SALT Shaker Podcast, Eversheds Sutherland Counsel Jeremy Gove and Chelsea Marmor unpack the complexities of Public Law 86-272, a federal statute enacted in 1959 to shield businesses from state income tax when their sole activity within a state is soliciting orders for tangible personal property. 

The conversation explores the law’s origins, historical context, its continued relevance in state tax litigation, and the MTC’s evolving guidance regarding internet-based activities.

Chelsea and Jeremy conclude the discussion by reviewing recent legal battles over the law in California, New York, and New Jersey, and exploring what these cases mean for the future of PL 86-272.

Tune in to find out how Jeremy returns to his favorite nontax tradition of overrated/underrated!

Questions or comments? Email us at SALTonline@eversheds-sutherland.com. Subscribe for regular updates from stateandlocaltax.com.

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Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award a prize for the smartest (and fastest) participant.

This week’s question: Which state is considering legislation that would apply graduated rates to its deed excise tax on real estate transfers to raise revenue for affordable housing initiatives?

E-mail your response to SALTonline@eversheds-sutherland.com.

The prize for the first response to today’s question is a $25 UBER Eats gift card. This week’s answer will be included in our SALT Shaker Weekly Digest, distributed on Saturday. Be sure to check back then!

Members of the Eversheds Sutherland SALT team are excited to participate in two state and local tax conferences this week: the Broadband Tax Institute (BTI) Annual Conference in Avon, CO, and the 2025 Institute For Professionals in Taxation (IPT) Sales Tax Symposium in Indian Wells, CA.

BTI Annual Conference

SALT Partners Todd Betor, Jeff Friedman, Charlie Kearns, Dan Schleuter, and Maria Todorova are pleased to speak at this year’s BTI Annual Conference. Sessions and speakers include:

  • Jeff Friedman – State Tax Litigation
  • Charlie Kearns – State Tax Policy
  • Dan Schleuter – Property Tax – Current Developments/Litigation
  • Todd Betor – Tax Planning Insurance 2.0 – A Deeper Dive
  • Maria Todorova – Federal & State Regulatory Fees & Transaction Tax Trends

2025 IPT Sales Tax Symposium

Members of our SALT team are also thrilled to present at the 2025 IPT Sales Tax Symposium. Counsel Jeremy Gove will highlight key considerations when preparing for litigation, including how to anticipate a judge’s approach to a tax case. Counsel Cyavash Ahmadi will help explore proactive strategies for combating the growing challenge of tax base creep, with a focus on both legal and collaborative approaches.

Find out more about this year’s symposium here.

Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award a prize for the smartest (and fastest) participant.

This week’s question: Which state introduced a bill authorizing its Department of Taxation and Finance to share taxpayer addresses with the state comptroller’s office to help return unclaimed funds?

E-mail your response to SALTonline@eversheds-sutherland.com.

The prize for the first response to today’s question is a $25 UBER Eats gift card. This week’s answer will be included in our SALT Shaker Weekly Digest, distributed on Saturday. Be sure to check back then!

Tags: Trivia

Meet our September SALT Pet of the Month, Misha! As far as her parents know, her name is Russian for teddy bear, and she is just as fluffy and cuddly as her name suggests. Misha is owned by the family of Shannon Brandt, who works at the Texas Comptroller’s office. Who wouldn’t want to come home to this sweet face after a long day of rulemaking or memo drafting?

Misha is a 5-month-old Airedale Terrier. Her current favorite treat is a tie between a peanut butter-filled Kong or licking the head of her feline best friend, Pepper. Misha recently graduated from puppy school and passed with flying colors. She’s still working on a few commands, like when her silly family tells her to stop chasing the cat, but she’s doing great with sitting for treats and walking nicely on her leash.

Misha is either a bouncing ball of energy or napping on the floor of Shannon’s office.

Welcome to the SALT Pet of the Month family, Misha!

On Wednesday, September 24, SALT attorneys Michele Borens, Jeff Friedman, Maria Todorova, Jeremy Gove and Chelsea Marmor will share their insights during the TEI Seattle Chapter‘s State and Local Tax Update.

Sessions and speakers include:

  • Jeff Friedman – WA DOR Update
  • Michele Borens and Maria Todorova – Litigation and Legislative Update
  • Jeff Friedman – It’s Time to Play…. Family Feud State Tax Edition: Managing your State Tax Controversy
  • Jeremy Gove and Chelsea Marmor – Challenging Assessments and Filing Protests

Find out more and register here.

Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award a prize for the smartest (and fastest) participant.

This week’s question: Which state recently amended its sales tax rule to clarify how retailers must separately state sales tax when no receipt is provided?

E-mail your response to SALTonline@eversheds-sutherland.com.

The prize for the first response to today’s question is a $25 UBER Eats gift card. This week’s answer will be included in our SALT Shaker Weekly Digest, distributed on Saturday. Be sure to check back then!

SALT Partners Jeff Friedman, Tim Gustafson and Maria Todorova look forward to joining the speaker lineup of the Council On State Taxation (COST) 56th Annual Meeting, held this week in Memphis, TN. Their panels will cover a range of critical SALT topics, including:

  • The most significant SALT issues businesses are facing in 2025 and 2026, including a focus on pending pivotal court decisions, audit issues and regulatory changes
  • Federal preemption and how it can limit state and local taxation
  • Sales and use tax challenges arising from tariffs

Learn more about this year’s conference and register here.

Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award a prize for the smartest (and fastest) participant.

This week’s question: The Department of Revenue for which southern state recently issued guidance on the application of the sales and use tax to digital products and related services?

E-mail your response to SALTonline@eversheds-sutherland.com.

The prize for the first response to today’s question is a $25 UBER Eats gift card. This week’s answer will be included in our SALT Shaker Weekly Digest, distributed on Saturday. Be sure to check back then!

With summer behind us and uniforms back in rotation, the school year is officially underway.

As fall settles in, we’ve captured some great moments of our SALT family kicking off the academic season.

The Eversheds Sutherland SALT team wishes you a successful and inspiring year ahead!

1, 2: Paralegal specialist Jaime Lane’s daughter Cassidy (8th grade) and son Cooper (10th grade)
3: Partner Charlie Kearns’ daughter Ella (3rd grade)
4: Partner Jonathan Feldman’s daughter Anna (10th grade) and son Micah (7th grade)
5: Counsel Charles Capouet’s daughters Charlotte (4th grade) and Chloe (Kindergarten)
6-8: Legal practice assistant Melissa Bragg’s daughters Madelyn (6th grade) and Emma (12th grade). Can’t forget the family’s furbaby, Lola, too!