In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor break down the business versus non-business income divide. They also explore how the Multistate Tax Commission’s recommended shift in terminology – from business/non-business income to apportionable/non-apportionable income – refocuses the analysis on whether income is constitutionally apportionable.
Chelsea and Jeremy then
In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor introduce federal preemption and how the Supremacy Clause limits state taxing authority. When federal and state laws conflict, federal law controls, requiring state law to give way.
Jeremy and Chelsea outline the two types of preemption: express and implied.
Drawing on
In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor break down two noteworthy Texas franchise tax decisions that provide important guidance on sourcing and federal preemption.
The hosts first discuss NuStar Energy LP v. Hancock, a Texas Supreme Court decision addressing how receipts from the sale of tangible personal
In this episode of the SALT Shaker Podcast, hosts and Partners Jeremy Gove and Chelsea Marmor welcome Lauren Loricchio, Investigations Editor at Tax Notes, to discuss the publication’s long‑standing commitment to government transparency and access to primary tax materials.
Lauren traces the origins of Tax Notes back to its 1972 lawsuit against the IRS
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
