Recent Cases and Challenges in Tax Litigation with Jordan Goodman: Part 2

Hosts & Guests

Judy Vorndran, Partner, State and Local Tax

Meredith Smith, State and Local Tax Senior Manager

Jordan Goodman, State and Local Tax Partner at Horwood Marcus & Berk Chtd.

 

What You Will Discover:

This week on the SALTovation podcast we continue our discussion on the ever-changing landscape of state and local tax. Jordan Goodman, Attorney at HMB Law, discusses the changing landscape of state and local tax, focusing on the investee allocation cases and the shift from considering the location of the business to the location of the asset being sold. He highlights the confusion and lack of clarity in state tax laws, emphasizing the need for uniformity and clear guidelines. Jordan also touches on the challenges of remote work and the impact of automation on tax audits.

 

 

Topics Discussed in this Episode:

  • The investee allocation cases have changed the game in state and local tax, shifting the focus from the location of the business to the location of the asset being sold.
  • The distinction between intangible and tangible assets is fading in the courts’ minds, leading to the treatment of the sale of an asset as the same as the sale of the thing that owns the asset.
  • State tax laws lack uniformity and clarity, causing confusion and challenges for businesses and tax professionals.
  • The rise of remote work and automation has made tax audits more efficient and increased the likelihood of audits for businesses of all sizes.

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Transcript

[00:00:05] Meredith Smith:Welcome to SALTovation. The SALTovation Show is a podcast series featuring the leading voices in salt, where we talk about the issues and strategies to help you make sense of state and local tax.

[00:00:16] Jordan Goodman: What do you think about the investee allocation cases? You know, the, uh, V. S. Holdings out of Massachusetts, Goldman Sachs, New York City, Metropolis out of California. It's changed the game. And it's, I tell people this, I've been doing this long enough where it was, you Every statute was written as the intangible That you sell ownership stock partnership escort, whatever Resides in the back wherever your corporate domicile is, right?

So i've got gain on selling an intangible asset. It's commercial domicile And what we've seen over the last year and a half two years Maybe is this shift to investee, right? It's not where i'm located. It's where the business is located You And the fallacy there is that the value may be generated by the business, but the thing that was sold, the asset that was sold is just ownership of the business, not the business.

And I fail to see the legal argument that the sale of an asset is the same thing as sell of the thing that owns the asset. And yet the states are treating them the same and they're winning. And I think the reason why is because it makes sense. That nuance between intangible and tangible is kind of fading in the court's minds and it's like well the business The assets themselves generated the profit But if it was a building and you sold a building in chicago Illinois would tax the heck out of it, right?

It's asset located here. They get 100 of the game I'm not sure why it changes with intangibles, but we're starting to see the states push back and you know We've had some minor wins, but their states have a lot of major wins in this case And they're getting there different ways, but I do see that as kind of a 2024 issue the continuation Of pushing out it's not in it's business as usual Where was your business if I sold it day one of the year if I sold it last day of the year middle of the year Doesn't matter In michigan again why the vectrum decision is so offensive to me is that it's an extraordinary year and yet they're saying We just look at the snapshot 2017 2019 whatever the year was that's all we care about what you did before doesn't matter what you do after doesn't matter We're going to look at this.

Right.

[00:02:31] Meredith Smith: Even though 20 years of activity led up to me being able to sell my business for 90 million or whatever it was or have 90 million of goodwill. It doesn't matter.

[00:02:41] Jordan Goodman: Right. No. Think about Armahammer baking soda, right? We used to use it a little pinch in our recipes. And then all of a sudden they figured out that if you put it in your refrigerator, it's, it absorbs all the bad smells, right?

Completely revolutionized that business. Right for baking soda and also everybody's got arm and had her baking soda in the refrigerator to keep the smells out Well that you know that does not Historical just you know, it's just a one time event. It changed the things and yet that's treated as just Okay, whatever your sales went up, we're going to look at what you were doing on the first 364 days of the year, not in the last.

Well, it's frustrating

[00:03:21] Meredith Smith: too. It's like there's the position, right? Like you said, you know, we are here to argue two sides of the case. The state has the same ability and could do the exact same thing for an out of state taxpayer. That's like, Oh, well, or an in state taxpayer that You know, regardless, there's, there's the contrary that the state can change their position on reasonably and they will.

[00:03:46] Jordan Goodman: Yeah, that's, that's extremely frustrating and, and I don't accept this as an answer. We're going to argue both sides of the case and we're going to let the courts decide, right? States should have a position That they they they the statutes written by the legislator signed by the governor proper revenue issues bulletins notices Regulations explaining it there's got to be some culpability.

There's got to be some responsibility that this is your position. Tell me your position You're charged with and this gets into deference, right? departments of revenue are charged with Knowing the most about their own statutes and regulations and because of that They're given deference Okay, if they if they take alternative positions that deference should be gone Because they're saying, I don't know, can we either way?

Well, then you shouldn't be the arbiter, the final arbiter, the interpreter that's entitled to 55 percent burden versus 45 percent burden, right? They shouldn't be entitled to that because they haven't made up their mind. You don't

[00:04:47] Judy: obviously sue the litigation if the state isn't asking for more. I mean, if everybody agreed that you owe less, then we wouldn't be fighting about it because in the end, it's about a state taking a position to have more than maybe they.

You know people perceive they're entitled to so It is them taking the possession that's in their best favor Which isn't always the best based on the facts the taxpayer or the law as written

[00:05:09] Jordan Goodman: All right But and you know, we don't have a lot of tax people in their drafting statutes That's one of our issues right?

And so the the scriveners are the The writers of these things try to do a good job. I'm going to give them credit. They do a lot of it, right? But words are so important in the tax world. Hey, just think about this I was just explaining to one of my young people the difference between apportionment and allocation isn't necessarily true because legislatures use both Allocation Right.

They're out the use of allocation really apportionment because they're looking at three factors. So You You know that lack of uniformity among the states is also Something that we're responsible for we've got to fight through

[00:05:54] Judy: that composite versus consolidated I mean, I think there's a lot of things that are not always clearly understood combined consolidated Like I don't think a lot of practitioners Always understand that and certainly people are preparing tax returns are not always attorneys So there's just a very different mentality there.

So interesting thought of some of those things, but it's very true You

[00:06:16] Jordan Goodman: I had a conversation last week with a pretty seasoned accountant. You guys will laugh at this. Marietta will laugh at this. It was a conversation that you may have had a dozen times last week. Was, okay, there's Public Law 86272 out there, but if states adopted Economic Nexus and they've adopted the MTC, Dollars of sales, 50,000 of property, 50,000 of payroll.

Well, what if I go over 500,000? Am I subject to tax? Well, what do you do? I sell tangible property remotely. Then you're still protected by 80, 60, 72. It's, it's, to me, it's clear as completely clear, but there's so much confusion out there because these statutes are saying, if you have this, and it doesn't say peren unless protected by 80, 62, 72 mm-Hmm.

It's just if you have of sales. You're subject to the income tax and seasoned accountants, not necessarily state and local tax people, but seasoned accountants preparing returns are still confused by that lack of uniformity and lack of clarity. Like

[00:07:21] Judy: I was saying this, um, the sets problem, every. Colorado that wants to participate in our sales use transactions.

And so has to have a wayfarer statute, which says, if you have nexus at the state, you have nexus in our city. It doesn't matter what the threshold is in the city. It just matters that the state, well, if you read that law straight up, you think I have to comply and so they can use that to enforce, even if the overriding situation is all cities aren't playing ball yet.

Who knows that part? Yeah. Oh,

[00:07:47] Jordan Goodman: it's the secret. I want you to roll out Roll out with all your power with all your persuasive powers I need you guys go out there to every local jurisdiction and say hey if you want a wafer statue wafer standard adopted Just adopt it. Tell us what the rules are Silence isn't good or tell us we follow state law and everything or something or for next just do something Give us a clue because without the clue Didn't

[00:08:14] Meredith Smith: chicago do that within the last couple years where they said?

All right. Well, illinois's got it. The city of chicago is going to have their hundred thousand dollar threshold on their

[00:08:25] Jordan Goodman: Well, that's a great point, and I've applauded the city of Chicago for doing it. I believe, I forget now, it was July 1st of 21. It was a go forward, safe harbor, 100, 000. But then in audit, they would go back to 2016 and try to enforce it. And you would compromise based upon October 1st of 2016. 2018 when the city adopted it.

Yeah Because they said well, we really didn't create a new standard Kind of looks like a new standard

[00:08:55] Judy: Anyway, it's not the wafer decision is not for cities. It's for the states So, I don't know, you know, but who's gonna take that up to litigate it depending on the money

[00:09:07] Jordan Goodman: depending on the money Right. So I applaud City of Chicago.

They were out there, they wrote a bulletin and then kind of backtracked a little bit

[00:09:15] Judy: and didn't follow the words. We have the same thing happening in California, or Colorado too. It's very, our, it's disheartening, I would just say.

[00:09:23] Jordan Goodman: California, Colorado, Chicago, Cook County. We can just, maybe it's just the C words.

Yeah, maybe. Jurisdictions, I mean

[00:09:34] Meredith Smith: if there's anything else to take forward with you, they're just that's it but we will kind of as we wrap up and jordan you had kind of mentioned this at least towards the kind of gain a alternative apportionment anything you hope continues to be Fought litigated brought more attention to you for 2024 going forward

[00:09:59] Jordan Goodman: Yeah, I mean, there's, there's a couple decisions that I think have to be done.

Certainly, the Amazon versus South Carolina decision as to whether a marketplace has responsibility and maybe they get into defining what it takes to actually have property in a state. That's the ultimate goal there. Now, in some ways, the retroactive application of marketplace May apply. I don't think it does.

I think they're really getting into ownership what it means and for a long time We've always thought that you know That I I remember this uh with my older brother We'd have a football and be my football and he would take it and go play with his friends and I go but that's mine He goes no no possessions nine tenths of a lot.

We used to throw that out all the time, right? Didn't even know what it meant eight years old My career in law was already started. Possession is nine tenths of a line. You know what I mean? But possession might be nine tenths of a law, right? Because if you look at the marketplaces they have possession control I've got ownership But if it's in their warehouse and they've got risk of loss And they control what it could be sold for and then where it could be sold and what they can do with it Maybe you got to add all those things up So I think that the south carolina be what uh amazon decision is going to be important is defining what ownership is and therefore owning Defining what physical presence is and property is I think that's going to be a really important decision I don't know that comcast in maryland, which we talked about anything will happen in 2024, but Ultimately, 25, 26, we'll get some decisions there about digital advertising, enforcement, fair enforcement, the impact of the Internet Tax Freedom Act, what is protected, what is not protected, the whole discrimination clause, can you discriminate against the internet?

You guys, Wayfair v Lockwood, right? That's me. Yeah, I can't read my right. Although,

[00:11:43] Judy: okay, I got to clarify this one. I thought this was a retroactive Wayfair application case, but we just had the attorney representing the city speak at a task force meeting last week or the week before, and they had physical presence.

That's what the facts say. So I'm like, wait a minute. I thought this was retroactive enforcement of Lakewood. You know, having a, have a wafer law and it's, they haven't done all the deposition. There's still fact finding to be done, but if there was a physical presence, either their own trucks, delivery, things like that, that's a different set

[00:12:16] Meredith Smith: of contractors.

You could sign up to have someone in build your microwave cart that you bought from Amazon to kind of like Ikea, but it's, it's physical presence historically.

[00:12:29] Judy: Possibly.

[00:12:30] Jordan Goodman: Okay, I I have a I have a question about that and I get asked all the time about independent contractors performing services if they're paid for by the customer not by the company and I my my Comparison is I'm, very fortunate here in chicago.

I get hired by people outside of chicago to litigate a case In texas in oregon or in new jersey new york There's the fact that they hire me as an independent contractor and i'm performing services for them in the city of chicago I mean, they're subject to tax in illinois. I'm an independent contractor They're paying me to perform services in the state that they benefit from and they may benefit from it here I always argue that no Professionals doing their job does not necessarily create physical presence independent contractor some of the large department stores That sell things they don't hire.

They don't have contractors They've got independent contractors that they have a website for or they've got chair sheets on They don't hire them We don't install garbage disposals, but here are some people that do And you call them up and you contract with them separately. Does that create physical presence in a state?

I you know, I i'm not sure that it does because if so all of the service providers that we represent that we are Create nexus for everybody. We do perform services for I think that's a real push. I think that's a real well even

[00:13:56] Judy: I think a parade show nexus, right? Just because it happens to be in nevada Or anywhere else for that matter, why is that enough to say you have nexus?

I mean, fortunately we have a few laws that say not, but still people do things wherever they want to do things. I mean, that's not necessarily, you're trying to build a market there. That's just a good location for people to come see your stuff. So I think that's a really interesting area that we're going to see.

Uh grow because you're just seeing more things more places That really have nothing to do with a physical presence Like i'm not really going here to build the market in this particular city or state I'm, just happy to join in with everybody else and that'll bring a bunch of bodies in to see my stuff So, I

[00:14:39] Jordan Goodman: don't know Purposeful, right?

That's right. That's what it gets to, right? Is that purposeful availment? Are there other things that i'm doing and i'm there or is it just the fact that i'm there? Without purposeful availment that doesn't make any sense because you're going to meet with it's a private meeting Whatever it was in house.

It might be totally fine But it's with some other people and we're all talking about the same stuff All of a sudden it says oh you have physical presence and then the question you raise is their purposeful And

[00:15:07] Judy: think about having a remote employee. Why is that considered nexus? Give me a break in a way that no way that person's making a market.

It's just a random They can happen to work from home and we like them That is not enough to create a duty in my opinion. That should go away in my

[00:15:25] Jordan Goodman: Right, I mean it gets back to what statistical presence where we get some some hope in wayfair v south carolina It still continues to be a major issue It's never good news when people ask me about it because I said, if you have people there, they're your employee.

You've got all the duties. I don't know any

[00:15:45] Judy: rules. All the duties. Unclaimed property, payroll, resale stocks, income tax. You're not

[00:15:49] Jordan Goodman: subject to all of it. Absolutely all of it. And I said, so decisions that we made three years ago, we'll come back to bite you here. And then you have the question on a labor shortage issue.

Can you afford to let these people go? Do you want to let them go? If they're a good worker, you absorb it just like anything else for a good, good worker, they get extra benefits. If they're not, you want to get rid of them anyway, it's a perfect opportunity to do that. You kind of take a practical approach, but you're right.

It was, you know, it was done for necessity purposes and now it's just been a thing. Yeah, and

[00:16:19] Judy: I was thinking that the average cost of compliance just to be in a state is probably three to five thousand a year. For all the tax returns, you got to file all the duties. You got to keep on top of a lot of tech companies have no idea what that even means.

You know, I mean, some people are just a pure remote. I mean, obviously, I don't even, are you the state? I just read an article, you know, how we don't have enough housing and they're thinking of taking over office towers and making them residential because there's just, we need more human. Of course, these weren't built for a lot of toilets, a lot of sinks, a lot of whatevers, but.

We're you know, we're not staying in our offices All

[00:16:54] Jordan Goodman: right. It's a shelter that then in um shopping malls for pickleball courts. That's the two big things in real estate right now Yeah, it's good use of real estate there's kind of vacancy tenancy rates are way down Repurpose redo it i'm okay with that makes sense

[00:17:10] Judy: And bring it all down and start

[00:17:13] Jordan Goodman: fresh Right.

No way more expensive to do that. Although if anybody's done home construction Sometimes it would have been easier to knock it all down and start fresh I live

[00:17:23] Judy: in 1895 victorian our Contractor is like you see that building next door that got built from the ground up much easier than what i'm dealing with figuring out your attitude

[00:17:34] Jordan Goodman: I got it All

[00:17:36] Meredith Smith: right, jordan.

So I guess as we do wrap up. Is there any do you have any parting words? Anything that you think our listeners should be left with other than your phone number for when states are really screwing things up?

[00:17:50] Judy: And I didn't realize you do litigation all over. So you'll do, you'll, you'll take a case all over the country.

Not just in illinois where you guys are heading

[00:17:59] Jordan Goodman: As active as illinois is from time to time Um, I like the diversity of not working just in illinois And i'm not worried about illinois being flush with money anytime soon So we'll always be looking for additional revenue, but I I like working all over It's just more fun going to see other people different laws different courts different judges different local council It's just fun to do it that way That's something i've been fortunate of and since i've started practicing as a video Go outside of illinois, which is and I would say illinois may be my single largest state.

It's close, but it's certainly Maybe 20

[00:18:35] Judy: percent of my business. That's a really big deal though, because part of the reason I'm a lawyer that I never went to a law firm was being limited by licensure and feeling like people have troubles across the nation. I need to help them. Right. And, um, and, and you don't always find that if you're too siloed and there's certainly enough within a home state to like keep you busy, but it's the differences that you look at and then.

Cost compare that helps you create better policy. Honestly, like look how Texas is doing this. So, and so I tell color all the time. You see, Texas is collecting on behalf of like 1714 jurisdictions, California, 256. We can't figure this out. What is wrong with us? And we're a very small state. So, yeah,

[00:19:14] Jordan Goodman: we're like that as well.

We're a bigger state, but we have the same local jurisdiction issue Um, you know, but it's interesting just uh aside from say tax paul franco It's kind of funny how many people don't remember paul, but paul litigated around the country And what he said is i've got a network of really great Friends that I trust and I get local council everywhere they go.

And that's what our practice is I learned I was mentored by him And so there's great people like you in colorado that I can always reach out to and say what's going on Can you help me with this? There's plenty of work for everybody. All right, and it's just it's the ability to have that network and state love facts people around the country We're a different breed.

I think it's better. I think it's great, but we're a very close knit community That generally enjoys each other's company presence outside of work I

[00:20:01] Judy: think obviously you're a cpa i'm a cpa an attorney like that's a kind of common mindset in the state and local area, I think a lot of times because There's just so many bits and pieces of the compliance that you kind of need to understand But so in addition to understand the legal issues a hand, you know

[00:20:21] Jordan Goodman: Interesting.

[00:20:22] Meredith Smith: I think there does need to be that spirit of collaboration because you can't know everything in every jurisdiction. It's impossible. So you have to reach out to those local experts.

[00:20:33] Jordan Goodman: Now in in the thing that you see being tripped up on it was a case just in Ohio I think it was where they failed to preserve an argument that was the best argument The high spring court ruled against it because they didn't preserve it local rules local procedural rules Are so important and I won't go into a state without contacting a friend in that state saying, okay Here's what here's what your role is.

I need you to get filed. I need you to do this You need to advise me what's unique about your process your procedures, california, new jersey, oregon Ohio, they all have these little quirks and you got to reach out. Yeah, I

[00:21:07] Judy: recently lost arbitration because we 20 day rule for factual disputes Not anywhere in writing But we were pronounced

[00:21:18] Jordan Goodman: Yeah, no exactly and that's why you kind of go in, you know with kind of defenseless Certainly behind the local person that you're fighting against when you don't know the and you can't know all the local ones You have to rely upon others, but I do want to make this one comment.

I want to put everybody on notice We're gonna see a lot and we've seen a lot more going on. I was kind of Thinking about that. Well, if you think about it, um Despite the pandemic, 2021 and 22 were banner years for businesses. They were tough years for states to adapt businesses adapted a lot of m& a action A lot of stuff going on in those period of time The states actually took a step back because their auditors were used to going to places couldn't go anywhere Right, so they're trying to catch up on all those years all those big transactions the increase in business The craziness the surrounded remote selling remote workers in 21 22 They think there's a big boot out there that will take them through the next five years And right now they're trying to step up and go after those years.

So anybody thinks well, it's been quiet I would say be on notice Yeah, audits are going to step up and the ability automation right teams zoom all the video conferences that we use right now They are used by the states as well You know one of the things that we used to do you go to a state you say i'm going to be in the state Can we get together?

It's almost impossible to do that with your stuff because they're not all It's a lot tougher, right? Auditors don't need to be at the corporate headquarters anymore. It's all from secure rooms offsite where you download information. That's a heck of a lot easier than trying to figure out how you're going to be in Oregon and Texas on

[00:22:57] Judy: the same day.

Interesting shift. It obviously you're even seeing a litigation. My husband's a litigator and he's like, Oh, I have something, a hearing. And he's like, Oh, it's remote. I'm like, I don't even have to show up. So he forgets that some things are in person and some things aren't, but it allows all the participants not to have to fly in.

Um in order to meet, uh, so he's you know, it's been a funny pivot for him Um, because you know, obviously things were that way during covet, but now they're continuing that way as well It's just easier

[00:23:24] Jordan Goodman: right because there's certain status conferences, right? It's no reason to go to court if it's dispositive evidentiary Different reasons, you get to see the face, you see coaching, you see other things, but you know, sort of court cases, every couple of months you got a status that you show up for and they go, how's it going?

Oh, we're still talking about our stipulation facts. 30 seconds, and then you move on. Okay, I'll set it for another 60 days. There's no reason I have to be in person. Which is a benefit, I think. And the same thing from the state side. State side, you get an IDR, They send it to you, they put it in the secure, right?

The secure messaging, right? You download it with your information. They look at it from wherever they want to. It's just more efficient and they can do a lot more auditors, a lot more audits because it's just going into a digital file somewhere, not physically looking at it. It's kind of amazing.

[00:24:10] Judy: We're in

[00:24:11] Meredith Smith: the middle of a Pennsylvania audit for one, I think, This could be another point to where they were, you know, kind of traditionally viewed as like a professional services firm, but, you know, kind of using computers as their backing.

So in Pennsylvania, though, there's kind of a carve out for kind of generally stuff associated with a computer, but we're getting audited. And, uh, you know, we had to upload SOWs, whatnot, to the portal and then there's some like, yep, we can just immediately send them down to Harrisburg because they're the ones making all of the decisions.

Like, I'm local auditor. I'm basically collecting all the data, but I have it right here. It's going to go somewhere else. And there's like the, the Pennsylvania Department of Revenue Brain Trust sitting in Harrisburg. That's going to make all the decisions quick, you know, with a lot of available information.

Because it's all online

[00:25:09] Jordan Goodman: No, and think about the digital room the share points The states now have the ability and there was some talk about this before and it got rolled out They know by industry, right? That's what they should be doing by industry Kind of what things should look like what margins should be what taxes should look like What this will look like based upon your size and what you're doing And they should be able to figure things out because it's like ai ai isn't art.

It's not intelligence Yes It's the ability to know more stuff at the same time, right? That's I mean, that's what the great Kind of fallacy. It's not they're not thinking on their own. I mean computers just have Capable of

[00:25:47] Judy: Yep

[00:25:52] Jordan Goodman: One auditor does 10 audits of booksellers. Okay, that's the only knowledge they have.

The computer has done a thousand audits of booksellers. There's all that much information, all that much data from all the different audits, and does then saying, here's our standard. This is where the range people should be in. This is what we're looking for. And if you're outside that range, They could they could zero on it right away.

That's that just makes it easier. That's why more people will be getting on It's not just a fortune 500 fortune 1, 000 fortune 5, 000 It's smaller people because they can identify the one sore spot That this particular business has so we're all going to start seeing these kind of electronic notices and electronic audits It makes some sense.

And if you go to any of the conferences put on by fta misada misada misto Sita, the thing they talk about more than anything else is automation Everything's about systems about needing less people to do more. And that's why we're going to see more and more of this because It makes sense. That's

[00:26:55] Meredith Smith: where we're going.

Thank you so much for being here. Thank you for your time today We could do a part

[00:27:02] Judy: three

[00:27:02] Meredith Smith: in another 15 months mid 24 Keep coming back. Um

[00:27:09] Jordan Goodman: It's just so easy to talk to you guys. There's so much going on. It's fun

[00:27:12] Judy: to know that you still have so much enthusiasm too, because it's such, I felt last year when I found out about our vendor fee in Colorado, I was like, I quit.

I can't take this because I didn't know about it. Normally I know things like that, but it was a transportation bill that I got passed. No one knew about it in the tax community. Department of Revenue was tasked on enforcing it. They don't want to tell anybody because they don't know what they're going to do with it.

And then we all find out in April, it was effective July. I'm like, I quit, how am I going to tell my clients how to figure this out? You know, that sort of stuff makes me crazy, you know, we would have that little notice, you know, to implement a 27 cent, which is now 28 cents. So, and now Minnesota's doing it.

I mean, some of that makes me a little like, oh my gosh, how do I help the clients? I, how are they going to do this? So those are things are challenging

[00:28:00] Jordan Goodman: well, but But you have to put yourself on the other side. Okay, but on the other side You have to help your clients because there's no way they'll figure it out.

So right you know someone I had a I was a biz dev guy a bunch of years ago, and he said do you feel like you do a good job? Like yeah, I do a good job. Do you feel like you help your clients? Yeah, I think I help my clients Then you should keep doing it and tell them that you could do it for them. You're we get compensated very well, no complaints about it, but you're also giving one heck of a great service to your clients and the people that you work with.

Well, it's funny. You

[00:28:32] Judy: think I have a client, say they're a 10 million company and you know, you're looking at. What, 80,000 of risks? No, 80,000 on a million. How much is the tax on eight? 110 million. Is it? 80 800,000 a year? 800,000 a risk. And you're talking about not spending, that's a year I gimme a break.

Like you don't understand what you're putting out there. That's, you gotta get your act around this. But there is this perception of like, it's a pass through or it's, it should be simple, easy peasy. And it's like, no, it's not. So shame on you for checking the same box and thinking it's applied. Universally across our nation.

So

[00:29:08] Jordan Goodman: it's only a pass through if you pass it through, you know, 8 percent is a nice profit margin for a lot of businesses. You take your profit margin and hand it over to the locals and hand it over to the state. Yeah.

[00:29:21] Meredith Smith: All right. Well, this is another episode of SALTovation till next time. This podcast is for educational purposes only and is not intended, nor should it be relied upon as legal tax accounting or investment advice to consult with a competent professional to discuss specifics of your Transcripts provided by Transcription Outsourcing,

[00:29:41] Jordan Goodman: LLC.