{"href":"http://player.captivate.fm/services/oembed?url=http%3A%2F%2Fplayer.captivate.fm%2Fepisode%2F3d53ddf7-daf7-4160-a6b0-0ce08367f729","version":"1.0","provider_name":"Captivate.FM","provider_url":"https://www.captivate.fm","width":600,"height":200,"type":"rich","html":"<iframe style=\"width: 100%; height: 200px;\" title=\"Litigating SALT Cases with Leah Robinson (Part 1)\" frameborder=\"0\" scrolling=\"no\" allow=\"clipboard-write\" seamless src=\"http://player.captivate.fm/episode/3d53ddf7-daf7-4160-a6b0-0ce08367f729\"></iframe>","title":"Litigating SALT Cases with Leah Robinson (Part 1)","description":"In the first episode of a two-part series, we chat with Leah Robinson, an attorney and state and local tax partner with Mayer Brown in New York. Leah talks about 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 \u201cgotchas\u201d that we should all be aware of.\r\n\n \r\n\nQuestions asked and answered in this Episode:\r\n\nWhat are some of the most interesting SALT cases that Leah has seen and litigated?\r\n\n\n \r\n\nWhat You Will Discover:\r\n\n[00:43] Leah\u2019s background\r\n\n[05:24] The first case she helped with the litigation\r\n\n[07:48] Her favorite cases to work on\r\n\n[12:58] The decision whether to litigate\r\n\n[20:08] The time it takes for private letter rulings and advisory opinions\r\n\n[24:18] Whether to pay or not pay\r\n\n\n \r\n\nQuotables:\r\n\n \r\n\n\u201cWhat do they do in some of the other courts when you need to know an answer, but there\u2019s no way to get one?\u201d- Leah Robinson [10:45]\r\n\n\u201cThere\u2019s a lot of sensitivities that go into the corporation\u2026, but the business side decision on whether to litigate, not just how likely are we to win, but all of these soft considerations. And often in my experience, those often rule the day.\u201d- Leah Robinson [16:51]\r\n\n\u201cIt\u2019s actually why it\u2019s so important for us to get along, right? There are a number of us who are direct competitors, but are also friendly and like connect with each other. Obviously, not breaking confidentiality provisions and closing agreements, but getting a sense of what\u2019s going on and what issues are we seeing go up, where the settlement ranges. We have to talk to each other, because the states know\u2026 you know, each individual department of revenue knows what it\u2019s doing with all different taxpayers.\u201d- Leah Robinson [18:32]\r\n\n\n\u201cIt\u2019s a huge issue to pay, but the bigger issue is if you don\u2019t pay, the interest becomes a whole other player in the analysis. And I have changed my story on this, right? I now advise companies for the most part to pay. \u2018Let\u2019s pay and seek a refund\u2019 or in some jurisdictions if we\u2019re litigating, we can pay and get an agreement with the state\u201d- Leah Robinson [25:00]\r\n","thumbnail_width":300,"thumbnail_height":300,"thumbnail_url":"https://artwork.captivate.fm/4fab4895-efd8-42bb-b0e1-4c7612ff4821/salt-1-bpay1.jpg"}