In this episode of the SALT Shaker Podcast, SALT Counsel Jeremy Gove and Chelsea Marmor dive into the nuanced world of state and local tax penalties.
They explore why penalty abatement standards, such as “reasonable cause” and “ordinary care,” remain ambiguous despite the frequent appearance of penalties in tax assessments. With limited statutory and
In this episode of the SALT Shaker Podcast, host and SALT Counsel Jeremy Gove sits down with Partner Tim Gustafson to explore the historical evolution and current challenges surrounding California’s sales factor.
The conversation traces California’s apportionment journey from its original equally weighted three-factor formula to today’s dominant single sales factor approach. Jeremy and Tim
In this episode of the SALT Shaker Podcast, SALT Counsel Jeremy Gove and Chelsea Marmor dive into the evolving intersection of artificial intelligence (AI) and SALT.
As AI technology continues to advance, Jeremy and Chelsea draw a parallel for tax purposes to the early days of the internet – when Congress passed the ITFA to
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
In the latest episode of the SALT Shaker Podcast, Eversheds Sutherland Counsel Jeremy Gove and Chelsea Marmor explore a new, concise podcast format that provides updates on recent noteworthy cases.
Jeremy and Chelsea examine a New Hampshire court’s decision in Hologic, Inc. v. Stepp, covering the facts, the court’s holding, the analysis, and the
In the latest episode of the SALT Shaker Podcast, Eversheds Sutherland attorneys Jeff Friedman and Jeremy Gove welcome UConn School of Law Professor Rick Pomp to discuss Jeff and Professor Pomp’s US Supreme Court cert petition in Ellingson Drainage, Inc. v. South Dakota Department of Revenue.
Jeff, Jeremy and Professor Pomp delve into the
In the newest episode of the SALT Shaker Podcast, Eversheds Sutherland Counsel Jeremy Gove takes a close look at San Francisco’s tax system with the help of Eversheds Sutherland Counsel John Ormonde and Bart Baer, Chief Tax Counsel for The California Taxpayers Association.
Jeremy, John and Bart review San Francisco from a tax perspective, specifically
In the latest episode of the SALT Shaker Podcast, Eversheds Sutherland Counsel Jeremy Gove welcomes Tyler Henderson, Senior Tax Manager at Amazon, for a discussion about Tyler’s experiences as a SALT practitioner.
Tyler sheds light on his journey to his current position, including why he chose to enter the tax field, what he enjoys about
In this episode of the SALT Shaker Podcast, Eversheds Sutherland Counsel Jeremy Gove welcomes back Sacramento SALT Partner Tim Gustafson for another California-focused conversation!
Tim and Jeremy base their discussion around a recent article Tim co-authored in Tax Notes State with Associate Sharon Kaur about the California FTB’s informal guidance.
Specifically, they delve into the
In this episode of the SALT Shaker Podcast, Eversheds Sutherland Associate Jeremy Gove welcomes Partner Jeff Friedman for another discussion of a landmark state tax case.
For this installment, Jeff and Jeremy jump into Moorman Manufacturing Co. v. Bair, discussing the history of 3-factor apportionment, and how the Moorman decision paved the way for
