In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor sit down with Counsel Charles Capouet to discuss his recent article in Tax Notes State on the use of declaratory judgments to challenge unconstitutional state taxes.
Charles explains how declaratory judgments can serve as a “third way” to contest a tax
In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor examine a pivotal moment in any state and local tax controversy: whether to take the next step after a tax assessment has been issued.
Jeremy and Chelsea walk through the key factors they consider when deciding whether to challenge an assessment
In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor unpack one of SALT’s highly discussed and fast‑evolving areas: digital services taxes.
Their conversation breaks digital services taxes into four distinct frameworks, helping listeners understand how states and localities are approaching the taxation of digital activity in different ways. The discussion
In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor break down a recent New York Appellate Division decision addressing a longstanding question in New York: Is providing a license to software always the sale of software?
Jeremy and Chelsea unpack the Appellate Division’s answer to that question in Beeline
In this episode of the SALT Shaker Podcast, Partner Jeff Friedman takes over as host and sits down with newly promoted Partners Jeremy Gove and Chelsea Marmor to celebrate their career milestones and reflect on the journeys that brought them here.
Jeff guides Chelsea and Jeremy through a conversation about their distinct professional paths, the
In this episode of the SALT Shaker Podcast, SALT Partners Jeremy Gove and Chelsea Marmor kick off 2026 with a lightning round of their favorite SALT issues from 2025.
They cover market-based sourcing, tax base expansions, remote worker litigation, and the classification of streaming services as tangible property. The conversation also touches on federal intervention
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
