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




National Law Review, Go-To Thought Leadership Award for Tax Law

Professional Memberships

Chicago Tax Club, Chair of Administration Committee

Chicago Bar Association, Member and Former Chair of State and Local Tax Committee

Illinois State Bar Association, Member of the State and Local Tax Council



  • Samantha K. Breslow Discusses Illinois Lawmakers Approving Budget with GILTI Addback with Law360June 2, 2021

    In an article by Law360, Samantha K. Breslow discusses Illinois Lawmakers approving the budget with GILTI addback. Read the full article by Law360 here. Illinois would require an addback for certain global intangible low-taxed income deductions, halt a phaseout of its franchise tax and temporarily cap net operating loss deductions under a $42.3 billion fiscal year 2022 budget that lawmakers…

  • State and Local Tax Illinois Practitioner SeriesSeptember 1, 2020

    In the Illinois Practitioner Series, HMB's SALT team discusses various topics covering Illinois Procedures, Corporate Income Tax, Retailers' Occupation Tax (Sales Tax) and Use Tax and Local Taxes. Download the full booklet here. Questions? Reach out to the state and local tax team here.  …

  • 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.…


  • Samantha K. Breslow Published in Tax Notes State - "Internet Tax Freedom Act: Protector From the Tax Man?"June 8, 2020

    In this second of a three-part series, Breslow discusses the Internet Tax Freedom Act and whether the digital world has really been protected from the tax man. Adoption and Intent of the ITFA Initially adopted in 1998 under the Clinton administration with the mantra “no new internet taxes,” the Internet Tax Freedom Act (ITFA) was made permanent on February 24,…

  • Chicago Mayor Announces Payment Extension for Local TaxesMarch 20, 2020

    On March 19, 2020, Chicago Mayor Lightfoot announced that the City of Chicago will extend the due date for “small businesses” to pay the following Chicago taxes to April 30, 2020: Bottled Water Tax, Checkout Bag Tax, Amusement Tax, Hotel Accommodations Tax, Restaurant Tax, and the Parking Tax. The City requires that taxpayers pay these taxes on or before the…

  • Samantha Breslow published in Tax Notes State - "Debugging the (State Tax) Code: Outdated Sales Tax Terminology"December 9, 2019

    Read the full article on Tax Notes here (subscription required). Samantha Breslow discusses how the sluggishness of legislation does not often adjust itself to the speed and terminology of technology. However, there are a few states that are adapting to overcome the discrepancies. Download a PDF of the full article here. Debugging the (State Tax) Code: Outdated Sales Tax Terminology…


  • Chicago Department of Finance Issues Nexus GuidanceJanuary 25, 2021

    On January 21, 2021, the Chicago Department of Finance (“Department”) issued an anticipated Information Bulletin (“Nexus Bulletin”) providing guidance on nexus and establishing a prospective “safe harbor” for certain taxes, including electronically delivered amusements under the Chicago’s Amusement Tax (“Amusement Tax”) Ordinance and nonpossessory computer leases taxed under the Chicago Personal Property Lease Transaction Tax (“Transaction Tax”) Ordinance.

  • Chicago Lease Transaction Tax Rate Increase for "Cloud" Software ProductsDecember 16, 2020

    On November 16, 2020, the City Council for the City of Chicago (“City Council”) amended the Chicago Personal Property Lease Transaction Tax Ordinance (“Ordinance”), eliminating the lower rate of tax on a nonpossessory lease of a computer, which includes “cloud” software products.

  • 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 and explores the interplay with the Illinois Retailers’ Occupation Tax (“ROT”).

  • 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.

  • 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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Chicago IL 60661

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