The SALT Show is an entertaining discussion of state and local tax issues for the busy tax professional. The SALT Show includes an update on state and local tax developments, interviews with state tax professionals, in-depth analysis of historic tax cases
The SALT Show Episode 94 (Update for Week of September 7, 2020) On this week's episode: Tax-related Developments in the California False Claims Act Speakers: William H. Gorrod, Baker Botts Partner Ben Geslison, Baker Botts Senior Associate
The SALT Show Episode 93 (Update for Week of July 20, 2020) On this week's episode: Ad valorem tax rates Property valuation Appraisal methods Speakers: Ben Geslison, Baker Botts Senior Associate Ali Foyt, Baker Botts Associate
The SALT Show Episode 92 (Update for Week of April 20, 2020) On this week's episode: State and local responses to the Coronavirus outbreak Disaster declarations Nexus considerations State conformity to federal relief
The SALT Show Episode 91 (Update for Week of February 24, 2020) On this week's episode: Digital advertisements in Nebraska Maryland's digital advertising gross revenues and services tax updates South Dakota's attempt to remove the sales tax exemption for advertising services West Virginia is considering a general data mining services tax Florida is looking to impose a sales tax on car-sharing companies Wayfair impacts in Missouri, Tennessee, Mississippi, and Kansas
The SALT Show Episode 90 (Update for Week of February 10, 2020) On this week's episode: CA, Inc. v. Pfeiffer United States v. Kovel, a 1961 case out of the Second Circuit How Kovel arrangements have succeeded and failed in the federal tax context
The SALT Show Episode 89 (Update for Week of December 15, 2019) On this week's episode: Overview of recent Texas decisions on treatment of hedging transactions and unitary business income ALJ opines on alternative apportionment and royalty exclusions in New York
The SALT Show Episode 88 (Update for Week of December 8, 2019) On this week's episode: Market-based sourcing and holding company legislation in North Carolina Nextel Part II - Pennsylvania litigation over net loss carryover caps (General Motors) Do you include VAT/GST in your sales factor denominator (California OTA decision) Arizona v. California - Solicitor General tells court to say no thanks
The SALT Show Episode 87 (Update for Week of December 1, 2019) On this week's episode: An overview of the MTC's December 2, 2019 whitepaper on Wayfair implementation and marketplace facilitators. Link to MTC Whitepaper
The SALT Show Episode 86 (Update for Week of November 24, 2019) On this week's episode: A brief update on state litigation against the feds over the $10,000 state and local tax deduction cap
The SALT Show Episode 85 (Update for Week of November 17, 2019) On this week's episode: Preview of Wayfair & marketplace facilitator legislative “fixes” Illinois has a constitutional problem? Banks fight back on Washington's B&O tax surcharge California treatment of disregarded partnerships
The SALT Show Episode 84 (Update for Week of November 10, 2019) On this week's episode: • Thoughts on revamping the show format • Don't overlook SALT on cross-border transactions Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 83 (Update for Week of November 3, 2019) On this week's episode: • Listener Contest: Economic nexus guess • California's latest on alternative apportionment regs • Look-through sourcing: Microsoft's Wisconsin case • Alternative apportionment attack on royalty companies (Staples) • Uber strikes back on local taxes Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 82 (Update for Week of October 27, 2019) On this week's episode: • Reflections on the COST 50th Annual Meeting • Update on MTC's working group to update PL 86-272 guidance for internet contacts • Mailbag Question: How do you combine taxpayers with different apportionment formulas? Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 81 (Update for Week of October 20, 2019) On this week's episode: • Missouri's 10-Year Refund Period • New Hampshire adopts market-based sourcing • Pennsylvania adopts an income tax nexus threshold • Wisconsin provides a brightline test for nexus based on employee presence • Labell v. City of Chicago – Chicago streaming tax upheld Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 80 (Update for Week of October 13, 2019) On this week's episode: • How to argue constitutional issues before administrative bodies • Louisiana constitutional amendment to allows Board of Tax Appeals to hear constitutional issues • Louisiana issues guidance treating GILTI as dividends • Florida queues up Wayfair and marketplace facilitator legislation • Preview of COST 50th Annual Meeting Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 79 (Update for Week of October 6, 2019) On this week's episode: • An overview of Texas Supreme Court oral arguments in several Texas franchise tax “cost of goods sold” cases, including Sunstate Rentals, American Multi-Cinema, and Gulf Copper • The California Office of Tax Appeals shuts down the Franchise Tax Board's 0.2% bright line test for taxing out-of-state members of LLCs doing business in California (Appeal of Jali). Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 78 (Update for Week of September 29, 2019) On this week's episode: • U.S. District Court dismisses states' claims that $10,000 SALT deduction cap is unconstitutional • An overview of the Utah Steiner case and implications for the external consistency test of apportionment • Kansas Attorney General strikes down Kansas Department of Revenue Wayfair notice • California sourcing of asset management services remains in limbo • A California Supreme Court showdown on ballot initiative taxes? Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 77 (Update for Week of September 22, 2019) On this week's episode: • Dividends received deduction litigation in Montana and Wisconsin • Connecticut digital goods sales tax legislation • California False Claims Act: Staving off the Sharks • Illinois passes mobile workforce safe harbor Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 76 (Update for Week of September 15, 2019) On this week's episode: • A primer on multistate taxation of business and nonbusiness income Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 75 (Update for Week of September 9, 2019) On this week's episode: • An overview of the South Carolina Administrative Court in Amazon Services LLC v. Department of Revenue • A status update on Normand v. Wal-Mart.com USA LLC Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 74 (Update for Week of September 1, 2019) On this week's episode: • Remote seller legislation makes its way to remote Nome – and musings on Wayfair implications for local sales tax • Another Texas court holds that telecom products do not qualify for the cost-of-goods-sold deduction • Updates on the never-ending saga of New Jersey GILTI guidance • Updates on the first meeting of the MTC's Wayfair Phase II working group. Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 73 (Update for Week of August 25, 2019) On this week's episode: • The end of Proposition 13 for business: will Californian's vote for a split roll? • Alaska severance tax hike initiative introduced • An update on the MTC's uniformity projects, including combined reporting/NOLs, Wayfair/marketplace facilitators part II, and PL 86-272 meets cookies Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 72 (Update for Week of August 18, 2019) • New Jersey withdraws its quirky GILTI apportionment notice • Kansas lawmakers may not be pleased with the DOR's crazy remote seller nexus position • A constitutional amendment to make it easier to pass local taxes in California fails & related litigation • How to retroactively elect out of technical terminations with the California Franchise Tax Board • Texas is floating a $500,000 franchise tax nexus threshold Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 71 (Update for Week of August 11, 2019) On this week's episode: Interviews with Sam Dibble and Jon Feldhammer on blockchain and federal tax issues A smorgasbord of state and local tax and unclaimed property issues involving blockchain and cryptocurrency Time Stamps: • Sam on the basics of blockchain 02:15 • Jon on IRS federal income tax enforcement 09:06 • Matt on state and local tax issues in the blockchain world 15:41
The SALT Show Episode 70 (Update for Week of August 4, 2019) On this week's episode: • An overview of the throw-back apportionment rule • An overview of the throw-out apportionment rule • Whirlpool Properties v. NJ Division of Taxation Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 69 (Update for Week of July 28, 2019) On this week's episode: • The saga continues: Pennsylvania severance tax legislation • Washington Supreme Court strikes down ban on local income taxes (Kunath v. Seattle) • Is the Oregon CAT referendum dead? • San Fran stock compensation tax on hold…for now • California market-based sourcing reg project: word on the street • New York draft apportionment regs & the unusual event rule • New York City going another direction on GILTI • New Hampshire getting frisky with other states • Texas treatment of retailers/wholesalers holding intangible rights in goods they sell Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 68 (Update for Week of July 21, 2019) On this week's episode: • An interview with Rusty Cannon, Vice President of the Utah Taxpayers Association on the latest in state tax policy Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 67 (Update for Week of July 14, 2019) On this week's episode: • A primer on judicial deference to administrative agencies in SALT litigation and the Kisor case • A couple of GILTI updates – Oregon and New York • Oregon passes CAT correction bill • Louisiana passes passthrough entity SALT deduction cap workaround • Texas cost of goods sold in the Supreme Court (AMC Theaters) Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 66 (Update for Week of July 1, 2019) On this week's episode: • A snapshot of key state tax issues through the lens of California • Marketplace facilitator legislation • Economic nexus thresholds • Federal conformity • Market-based sourcing • Alternative apportionment • Are unitary relationships carryover tax attributes? Song: (More Bounce in) California by Soulkid #1 Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 65 (Update for Week of June 30, 2019) On this week's episode: An overview of the latest legislation in Illinois A primer on successor liability laws for taxes and how to protect your company Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 64 (Update for Week of June 23, 2019) On this week's episode: A quick overview of the US Supreme Court's opinion in the Kaestner Trust case (with more to come) A primer on how the interstate sales tax credit system works for items subject to tax in multiple jurisdictions Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 63 (Update for Week of June 16, 2019) On this week's episode: • Washington has made big changes to its Business and Occupation (B&O) tax that may catch businesses off guard • Washington's real estate transfer tax on entity transactions gets harder to avoid; new graduated rates Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 62 (Update for Week of June 9, 2019) On this week's episode: • Learn all about Oregon's new commercial activity tax in Pacific Northwest Update Part I • The manufacturing exemption: when does manufacturing start? An Ohio case study Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 61 (Update for Week of June 2, 2019) On this week's episode: • Colorado water's edge litigation (Agilent & Oracle) and pending legislative “fix” • Will states apply Wayfair to income tax nexus? The other shoe is dropping. Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 60 (Update for Week of May 26, 2019) On this week's episode: • An overview of states' efforts to implement real-time sales tax remittance obligations on payment processors Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 59 (Update for Week of May 19, 2019) On this week's episode: • A quick update on sales thresholds for remote sellers • Texas Constitutional amendment prohibiting income taxes and its franchise tax implications • Oregon passes a quasi-gross receipts tax • Alabama Supreme Court rules that all software is taxable Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 58 (Update for Week of May 12, 2019) On this week's episode: • An overview of the pass-through entity tax regimes enacted in Connecticut, Wisconsin, and Oklahoma to work around the federal $10,000 deduction cap. Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 57 (Update for Week of May 5, 2019) On this week's episode: • Utah Legislature responds to the See's Candies transfer pricing litigation • Update on SSUTA and Louisiana litigation touching on Wayfair issues • Illinois marijuana tax proposal Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 56 (Update for Week of April 28, 2019) On this week's episode: • Oregon's proposal for a gross receipts tax • Taxing the high earners • Update on MTC's Finnegan project Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 55 (Update for Week of April 21, 2019) On this week's episode: • The nuts and bolts of getting state private letter rulings Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 54 (Update for Week of April 14, 2019) On this week's episode: • New Jersey's recent guidance on partnership reporting of business interest limitations under IRC Sec. 163(j) • Oral arguments in Agilent and Oracle on water's edge exclusion of holding companies. Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 53 (Update for Week of April 7, 2019) On this week's episode: • An overview of the proposed Digital Goods and Services Tax Fairness Act Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 52 (Update for Week of March 31, 2019) On this week's episode: • Massachusetts Using Taxes to Combat Pigeon Poop • Chicago and Illinois Efforts to Tax Streaming Services (and Maybe Law Firms) • OSSBRA Wayfair Legislation Reintroduced • Pennsylvania Severance Tax Proposal Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 51 (Update for Week of March 24, 2019) On this week's episode: • An overview of the Foreign Commerce Clause's prohibition on discrimination against foreign commerce and how it might apply to GILTI Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 50 (Update for Week of March 17, 2019) On this week's episode: • An overview of federal nexus legislation and prognosticating the post-Wayfair future Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 49 (Update for Week of March 10, 2019) On this week's episode: • New York's Pied á Terre Tax Proposal • Will California Kill the Board of Equalization? • Maryland Digital Goods Sales Tax Bill Dies • New Jersey Royalty Addback Litigation: Lorillard Tobacco Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 48 (Update for Week of March 2, 2019) On this week's episode: • Arizona legislative update: sales taxation of digital goods and cloud computing • California legislative update: sales tax on services provided to businesses • Federal legislative update: Mobile Workforce back before the Senate • Primer: Commerce Clause protections for foreign commerce Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify
The SALT Show Episode 47 (Update for Week of February 24, 2019) On this week's episode: • Arizona trying to shut down tax funding for municipal bands • California looking to impose a statewide sugary beverage tax • New Hampshire takes on the rest of the country • New Jersey GILTI reduction • Colorado cases on water's edge corporations set for oral arguments • Connecticut mulling sales tax on digital goods and services Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay
The SALT Show Episode 46 (Update for Week of February 17, 2019) On this week's episode: • Worldwide Combination Updates in Illinois and Massachusetts • More on Sales Taxation of Digital Goods • GILTI/163(j) Updates from Virginia Link to the Associated Taxpayers of Idaho Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay
The SALT Show Episode 45 (Update for Week of February 10, 2019) On this week's episode: • The Latest on State Taxation of GILTI • More on Sales Taxation of Digital Goods • Apportionment Litigation in Virginia • Must Your Valentines Gift Exceed 50# in Idaho? Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay
The SALT Show Episode 44 (Update for Week of February 3, 2019) On this week's episode: • Using Taxes as Political Weapons • Update on Taxation of Digital Goods • Is the Water's Edge Eroding? • Centralization of Local Sales Taxes • Update on Federal Wayfair Legislation Links to share the podcast with colleagues: bakerbotts.com, iTunes, Stitcher, GooglePlay
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