Samantha K. Breslow Associate
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Samantha K. Breslow

Sam is a member of HMB’s State and Local Tax (SALT) Group. Her practice spans SALT litigation and planning on issues involving income tax, sales and use tax, franchise tax and local taxes.

Sam works with publicly-traded and privately-held multinational corporations, multistate middle market businesses and high-net-worth individuals. Her background as a multistate tax consultant at Deloitte Tax LLP gives her a unique perspective and practical understanding of state tax compliance that she applies when working with clients.

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Multi-State Perspective, Strong Accounting Background

Clients rely on Sam’s understanding of all sides of tax compliance issues and experience in public accounting to mitigate and resolve SALT planning and litigation issues.


University of Illinois College of Law, J.D., magna cum laude

The University of Texas, B.A. in English and Spanish, University Honors



Professional Memberships

Chicago Bar Association, Chair of State and Local Tax Committee

Illinois State Bar Association, Member

Chicago Tax Club, Chair of Administration Committee



  • Samantha Breslow Discusses Chicago's "Cloud Computing Tax" with Bloomberg Law NewsSeptember 16, 2019

    Auditors in Chicago have been aggressively asserting that businesses have tax duties under the "cloud computing tax" because of their economic presence, or the volume of business they conduct within the city. In an article by Bloomberg Law News titled "State of Wayfair: Economic Thresholds Sneak Into Chicago Audits" by Michael J. Bologna, Samantha Breslow explains that the problem is…

  • Samantha Breslow Discusses Chicago's Tax on Cloud-Based ProductsSeptember 10, 2019

    At the beginning of 2016, Chicago implemented a unique method to tax businesses for their use of remote computing services, also known as the cloud. The Personal Property Lease Transaction Tax program collected $13.9 million during its first six months and rose to $42.2 million through 6/30/18. In an article by Bloomberg Law News, Samantha Breslow explained that Chicago is…

  • Samantha Breslow is appointed to Chair of the Chicago Bar Association's State and Local Tax CommitteeAugust 21, 2019

    After serving as Vice Chair of the Chicago Bar Association's SALT committee last year, Samantha Breslow has been appointed as the 2019-2020 Chair. Learn more about Chicago Bar Association here.…


  • Applying the Chicago Lease Transaction Tax to “Cloud” Software ProductsSeptember 11, 2019

    In a prior post, I explained the basics of the Chicago Personal Property Lease Transaction Tax (“Transaction Tax”), including the applicability of the tax to tangible personal property and software, potentially applicable exemptions and exclusions from the tax, and collection issues. This follow-up post in the Practitioner Series further clarifies the application of the Transaction Tax to “cloud” software products…

  • Chicago and Cook County Amusement TaxJanuary 8, 2019

    Although the Chicago and Cook County amusement tax are imposed similarly on taxpayers, they are independently administered taxes that feature key differences. Both the Chicago Amusement Tax Ordinance and Cook County Amusement Tax Ordinance impose the tax "upon the patrons of every amusement" within the city or county, but require the owner, manager, or operator of the amusement to collect the tax from each patron and remit the tax to the Chicago Department of Finance or the Cook County Department of Revenue.

  • Application and Abatement of Penalties in Chicago and Cook CountySeptember 11, 2018

    For taxpayers surprised to find their business caught in the crosshairs of a Chicago or Cook County audit, substantial penalties can also be an alarming challenge. In a prior post, I outlined penalties assessed by the Illinois Department of Revenue ("Department"), the basis for relief, and the process for seeking penalty abatement. Although the basis for relief is similar for Chicago and Cook County penalties, there are key differences in the procedure and requirements for seeking penalty abatement.

  • Application and Abatement of Penalties in IllinoisAugust 14, 2018

    At the close of an audit, in addition to tax and interest, a taxpayer may also be assessed various types of penalties that can be substantial and even surpass the underlying tax liability. However, there are several courses of action for seeking penalty abatement, which can often prove to be a worthy exercise for taxpayers.

  • Wayfair and its Impact on Illinois' Economic Nexus LegislationJune 26, 2018

    The Commerce Clause and interstate commerce were thrust into the spotlight last week, as the United States Supreme Court reversed the longstanding physical presence standard for sales tax nexus.

  • University of Illinois College of Law, J.D., magna cum laude
  • The University of Texas, B.A. in English and Spanish, University Honors
  • Illinois
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