The SALT Shaker Podcast

In this episode of the SALT Shaker Podcast, Partner Jeff Friedman sits down with Counsel Greg Matson to discuss his move to Eversheds Sutherland and reflect on a career spanning nearly every corner of state and local tax. Greg shares insights from his time leading the Multistate Tax Commission (MTC), including the organization's core programs and its push for greater uniformity in state tax laws....

In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor are joined by Counsel Charles Capouet to break down Illinois' sweeping new tax legislation passed at the close of its legislative session, and signed by Governor Pritzker on Tuesday, June 16. The group walks through several significant new taxes targeting the digital economy, including the newest state to impose a...

The long-awaited New York State budget Governor Hochul signs New York FY 2027 Budget into law | SALT Shaker Governor Hochul signs New York FY 2027 Budget into law | SALT Shaker has arrived, and while it may not have produced major headline-grabbing tax increases, there's plenty beneath the surface worth unpacking. In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor...

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 Je...

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 examples from technology, services, and digita...

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 property are sourced for franchise tax purposes....

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, which paved the way for public access to t...

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, allowing taxpayers to seek an early, definitive ruling on a ta...

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 following an audit. They emphasize that the decision is rarely straigh...

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 covers Mary...

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 , who offered its customers a license to taxable prewritten...

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 value of in‑person collaboration, and the satisfacti...

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 AI regulation, the ongoing...

In this episode of the SALT Shaker Podcast, SALT Counsel Jeremy Gove and Chelsea Marmor break down key New York tax and administrative developments shaping 2025. Their discussion includes: The proposed agenda of the incoming New York City mayor Significant personnel and administrative changes in New York City Recent court rulings on the retroactivity of the corporate income tax regulations Emergin...

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 case law guidance, these standards often le...

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 unpack...

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 avoid taxes stifling innovation. They explore whether the existing framew...

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...

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 case's practical implications. They wrap up the epi...

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 case's background and its various implications, particula...

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 discussing its various gross receipts taxes,...

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 his role and what drives him to serve in the educational sec...

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 work of the F...

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 states shifting to single-sales factor apporti...

In this episode of the SALT Shaker Podcast, Federal Tax Partner Mary Monahan joins Associate Jeremy Gove for a discussion of Moore v. United States .  Ahead of the oral argument scheduled for December 5, Mary provides Jeremy with a federal tax perspective about the case, including covering the case's background, the tax constitutionality issue before the Supreme Court, the legal arguments presente...