Episode 97

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Published on:

28th Aug 2024

Winning Strategies: How to Approach SALT Litigation with Sam Breslow

In this episode of the SALTovation podcast, we speak with Samantha Breslow, a seasoned expert in state and local tax, who is serving as a prominent attorney at HMB, a firm recently acquired by Kilpatrick. Sam shares her thoughts on the intricacies of tax compliance, the significance of maintaining professional relationships, and the hurdles faced when dealing with aggressive tax authorities. Listen as we take a deep dive into the Colorado local tax landscape, revealing the challenges and strategies for navigating the state's unique taxing jurisdictions. 

Check out the VVF Intervest LLC v. Harris - BTA Case No. 2019-1233 (Sept.13, 2023) case here. 


Key Takeaways:

  • Navigating Career Transitions: Sam's transition from aspiring family lawyer to tax attorney emphasizes the importance of flexibility and open-mindedness in career paths.
  • Complex Tax Cases: The episode highlights challenging cases like the Illinois business non-business income issue and the Tractor Supply decision in South Carolina, offering insights into tax litigation strategies.
  • Colorado Local Tax Nuances: An in-depth look at Colorado's taxing jurisdictions sheds light on the complexities of local compliance and strategic voluntary disclosures.
  • Impact of Professional Relationships: Maintaining relationships within the industry plays a crucial role in career development and effective case management.
  • Evolving Tax Laws: Discussions around the VDF case, digital services taxation, and leveling the playing field in Illinois underscore the dynamic and ever-changing nature of state and local tax laws.

Quotables

  • "There aren't that many wins in the scheme of things, at least within my career so far, because we do ultimately resettle a lot because it's in the best interest of the taxpayer a lot of the times to settle.” -Sam Breslow [13:16]
  • "When a state doesn't modify their ordinance or their statute but changes the way that they're doing things, I don't know if that's necessarily right.” -Sam Breslow [20:00]

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About the Podcast

SALTovation: Making Sense of State and Local Tax
Welcome to SALTovation. The SALTovation show is a podcast series featuring the leading voices in state and local tax (SALT). Here we talk about issues, strategies, and planning tools to help you make sense of SALT. Because, in SALT, there is no “one and done.” SALT is a puzzle of ever-changing pieces. Solving that puzzle is our business at SALTovation. Tens of thousands of listeners know they won't get tax talk as usual with the SALTovation team. Our team is known for straight-talk with a flair for fun, providing clarity and opinions that move businesses forward with confidence.

Attorney, CPA, speaker, and writer Judy Vorndran leads the SALTovation team as they go inside business to help deal with the daily operations and long-term strategies of making SALT less “taxing.” Judy has spent more than 25 years advocating for businesses with innovative strategies, renowned knowledge and experience. She has helped guide thousands of taxpayers across the nation and globally through the morass of SALT, freeing them to concentrate on growth. Joining Judy are the wickedly smart members of the SALTovation team, who have seen, worked with and tamed some of the most prickly issues in SALT. They enjoy sharing their stories and knowledge with listeners.

Solving the SALT puzzle doesn’t happen in a vacuum; it takes a community. So, we invite leaders in business and state and local tax to share their stories, challenges and successes on this show. Drop us a line at SALTovation.com if you'd like to join the conversation and tune into our regular series at TaxOps.com.