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GeTtin’ SALTy Episode 59: California SALT Update: AG Opinion Shakes Up OTA Authority, Conformity, and Litigation Looms [Podcast]
Wednesday, August 27, 2025

You are invited to listen to a new episode of GT’s GeTtin’ SALTy podcast, “California SALT Update: AG Opinion Shakes Up OTA Authority, Conformity, and Litigation Looms.” 

In this episode, host Nikki Dobay is joined by fellow Greenberg Traurig Shareholder Shail Shah to discuss the latest developments on the California state tax front. 

They start with a breakdown of the Attorney General opinion affirming the Office of Tax Appeals’ (OTA) authority to apply statutes over conflicting regulations, a shift that should positively impact taxpayer appeal rights and case outcomes. 

They discuss the history of California Board of Equalization’s authority to review regulations, and how the AG opinion is a deviation from past authority and what this means for future tax disputes. 

Shail and Nikki also discuss the legislative landscape as the session nears its end, and where conformity bill (SB 711), which would updated California’s alignment to the Internal Revenue Code for the first time in a decade, is at in the process, highlighting what taxpayers can expect if the bill passes. 

The episode covers ongoing litigation over SB 167, the 2024 budget bill, detailing the key constitutional issues at stake and what to watch at the upcoming summary judgment hearing. 

Rounding out the episode, Nikki asks Shail a fun non-tax question about his college days as “DJ ShelShock.”

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