Litigating SALT Cases with Leah Robinson (Part 2)
In the second episode of a two-part series, we continue our conversation with Leah Robinson, an attorney and state and local tax partner with Mayer Brown in New York. Leah continues to discuss some of the most interesting tax cases she has litigated, her thoughts on what could be deemed government overreach, and where she has seen some recent state auditor “gotchas” that we should all be aware of.
Questions asked and answered in this Episode:
- How Leah approaches each case
- After being at the IRS and then representing clients against the state, how does she feel about the mentality with the IRS and the state?
- Where she sees government overreach beyond what is allowable under the constitution
What You Will Discover:
- [00:24] How Leah decides how to approach each case
- [02:38] The mentality between the IRS vs the state
- [06:24] Looking how a product functions from a tech point of view
- [10:27] Examples of overreach
- [15:09] Where she sees government overreach
- [28:06] An interesting thing about the compliance effort
Quotables:
- “There definitely are cases where we want an answer. We need the answer, and if we can have a settlement that also gives us a going forward answer, fine, but you can’t always get that.”- Leah Robinson [01:57]
- “And I get it. The business folks in a company want to describe themselves a certain way. They want to appeal to their client base, but that doesn’t mean that that’s what the technology really is doing.”- Leah Robinson [06:45]
- “I think post-Wayfair, there’s been an assumption that economic nexus is the end of the story.”- Leah Robinson [15:45]
- “I still think physical presence is an easier standard, and cookies, even though they are intangibles, they still take up space, right? My hard drive has a limited amount of space. So even things that are intangible like software, they still take up space on the server, on a hard drive, etc.”- Leah Robinson [25:35]
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Production Support
This episode was produced with support from Truth Work Media. www.truthworkmedia.com
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