Texas-based attorney specializing in state and local tax (SALT) planning and controversy.
Dennis earned his J.D. at the University of Minnesota Law School, where he was a member of the Ronald M. Mankoff Tax Clinic. He also holds an LL.M. in Taxation from Georgetown University Law Center with a Certificate in State and Local Taxation.
Prior to beginning his studies at Georgetown, Dennis worked in the legal division of Thomson Reuters for seven years and served as an editor at The Dallas Morning News, the largest newspaper in Texas.
Dennis is licensed in Texas and the District of Columbia. He splits his time between Dallas and Houston.
Recent Publications
“Highlights from the 2023 Texas Comptroller’s Annual Briefing,” Salt Shaker.
“The Texas R&D Credit: Comptroller’s Regs Could Hogtie Taxpayers,” State Tax Notes (Cover).
“What’s the scoop on Texas’s research and development (R&D) credit?,” Salt Shaker.
“Getting SaaSy: Mississippi proposed sales tax rule targets cloud computing,” Salt Shaker.
“California Office of Tax Appeals shuts down refund claim related to 338(h)(10) election,” Salt Shaker.
“Something smells like a tax: California Supreme Court says waste management fee may be illegal tax,” Salt Shaker.
“Washington Department of Revenue finds sales tax must be collected on sales of renewable energy equipment,” Salt Shaker.
“A Texas-sized legislative update,” Salt Shaker.
“The Texas R&D Credit: Comptroller’s Regs Could Hogtie Taxpayers,” State Tax Notes (Cover).
“Highlights from the 2022 Texas Comptroller’s Annual Briefing,” Salt Shaker.
“The Year That Left Us SALT-y: Key State and Local Tax Developments in 2020,” Tax Executives Institute (TEI) Magazine.
“Destined for the Courtroom—Illinois Audit Program Won’t Stop Sales Tax Litigation,” Bloomberg Tax.
“Maryland’s Proposed Digital Advertising Tax (HB 732) – Insights and Analysis,” Salt Shaker.
“Ownership of Tennessee Mortgages Does Not Create Nexus for Foreign Investment Fund,” Salt Shaker.
“Louisiana Loses Jeopardy!,” Salt Shaker.
“Tough cheese: Wisconsin Tax Appeals Commission clarifies the scope of property tax manufacturing exemption,” Salt Shaker.
“Trouble at the Pump: Indiana Department of Revenue Concludes that a Holding Company is not Unitary with a Gas Station Partnership,” Salt Shaker.
“California’s Flawed Proposal to Expand False Claims Act to Tax,” Tax Notes.
“The Long Road to Clarity: FTB Holds Latest Meeting in Multiyear Project to Clarify Alternative Apportionment Petition Process,” Salt Shaker.
“Hearing Held on Controversial California Corporate Tax Disclosure Bill,” Salt Shaker.
“New Mississippi Marketplace Facilitator Law Leaves Food Delivery Services off the Menu,” Salt Shaker.
“Georgia DOR Rules that Sales Tax does not Apply to Most of Taxpayer’s Healthcare Document Management Services,” Salt Shaker.
“Maine Takes a Jumbo Slice of Taxpayer’s $3.6 billion Frozen Pizza Business Sale,” Salt Shaker.
“Michigan Supreme Court Rules Service Revenues Must be Sourced to the Location where the Services are Performed for City Income Tax Purposes,” Salt Shaker.
“Md. Digital Ad Tax Likely To Share Fate With Wash. Bank Tax,” Law360.
“California Court of Appeal holds that taxpayer must pay up before challenging a tax regulation’s validity,” Salt Shaker.
“If Md.’s Digital Ad Tax Is Passed, Court Challenges Will Follow,” Law 360.
“Inside California’s Office of Tax Appeals,” Eversheds Sutherland.
“California Tax Appeals Office Shows Impartiality In Its 1st Years,” Law360.
“Big Changes Proposed for Maryland Opportunity Zones,” Tax Notes.
“South Carolina Gets SaaS-y, Taxes Software Subscription Services,” Salt Shaker.
“Important Considerations from the MTC’s Draft 2019 Marketplace Facilitator White Paper,” Salt Shaker.
“Legal Alert: MTC Uniformity Committee considers updated marketplace facilitator white paper,” Eversheds Sutherland.
“Marketplace Monday: To Be or Not To Be A Seller,” Salt Shaker.
“How States Protect Marketplace Facilitators from Tax Overcollection Lawsuits,” Salt Shaker.
“Why a taxpayer’s carbon reactivation process is ineligible for Texas’ manufacturing sales tax exemption,” Salt Shaker.
“Marketplace Monday: You Might Be A Marketplace If…,” Salt Shaker.
“Get Your Refunds: New Jersey’s Alternative Minimum Tax Preempted by P.L. 86-272, Tax Court Says,” Salt Shaker.
“4 State Responses To Opportunity Zones,” Law 360.
“New York Disregards Taxpayer’s Reliance on Disregarded Entity Rules,” Salt Shaker.
“Tax Perspectives On Kisor V. Wilkie: Part 2,” Law 360.
“Tax Perspectives On Kisor V. Wilkie: Part 1,” Law 360.
“Indiana Supreme Court Cites Business Purpose Requirement in Holding RV Dealership Liable for Uncollected Sales Tax,” Salt Shaker.
“The Texas R&D Credit: Comptroller’s Regs Could Hogtie Taxpayers,” State Tax Notes (Cover).
“Highlights from the 2022 Texas Comptroller’s Annual Briefing,” Salt Shaker.
“The Year That Left Us SALT-y: Key State and Local Tax Developments in 2020,” Tax Executives Institute (TEI) Magazine.
“Destined for the Courtroom—Illinois Audit Program Won’t Stop Sales Tax Litigation,” Bloomberg Tax.
“Maryland’s Proposed Digital Advertising Tax (HB 732) – Insights and Analysis,” Salt Shaker.
“Ownership of Tennessee Mortgages Does Not Create Nexus for Foreign Investment Fund,” Salt Shaker.
“Louisiana Loses Jeopardy!,” Salt Shaker.
“Tough cheese: Wisconsin Tax Appeals Commission clarifies the scope of property tax manufacturing exemption,” Salt Shaker.
“Trouble at the Pump: Indiana Department of Revenue Concludes that a Holding Company is not Unitary with a Gas Station Partnership,” Salt Shaker.
“California’s Flawed Proposal to Expand False Claims Act to Tax,” Tax Notes.
“The Long Road to Clarity: FTB Holds Latest Meeting in Multiyear Project to Clarify Alternative Apportionment Petition Process,” Salt Shaker.
“Hearing Held on Controversial California Corporate Tax Disclosure Bill,” Salt Shaker.
“New Mississippi Marketplace Facilitator Law Leaves Food Delivery Services off the Menu,” Salt Shaker.
“Georgia DOR Rules that Sales Tax does not Apply to Most of Taxpayer’s Healthcare Document Management Services,” Salt Shaker.
“Maine Takes a Jumbo Slice of Taxpayer’s $3.6 billion Frozen Pizza Business Sale,” Salt Shaker.
“Michigan Supreme Court Rules Service Revenues Must be Sourced to the Location where the Services are Performed for City Income Tax Purposes,” Salt Shaker.
“Md. Digital Ad Tax Likely To Share Fate With Wash. Bank Tax,” Law360.
“California Court of Appeal holds that taxpayer must pay up before challenging a tax regulation’s validity,” Salt Shaker.
“If Md.’s Digital Ad Tax Is Passed, Court Challenges Will Follow,” Law 360.
“Inside California’s Office of Tax Appeals,” Eversheds Sutherland.
“California Tax Appeals Office Shows Impartiality In Its 1st Years,” Law360.
“Big Changes Proposed for Maryland Opportunity Zones,” Tax Notes.
“South Carolina Gets SaaS-y, Taxes Software Subscription Services,” Salt Shaker.
“Important Considerations from the MTC’s Draft 2019 Marketplace Facilitator White Paper,” Salt Shaker.
“Legal Alert: MTC Uniformity Committee considers updated marketplace facilitator white paper,” Eversheds Sutherland.
“Marketplace Monday: To Be or Not To Be A Seller,” Salt Shaker.
“How States Protect Marketplace Facilitators from Tax Overcollection Lawsuits,” Salt Shaker.
“Why a taxpayer’s carbon reactivation process is ineligible for Texas’ manufacturing sales tax exemption,” Salt Shaker.
“Marketplace Monday: You Might Be A Marketplace If…,” Salt Shaker.
“Get Your Refunds: New Jersey’s Alternative Minimum Tax Preempted by P.L. 86-272, Tax Court Says,” Salt Shaker.
“4 State Responses To Opportunity Zones,” Law 360.
“New York Disregards Taxpayer’s Reliance on Disregarded Entity Rules,” Salt Shaker.
“Tax Perspectives On Kisor V. Wilkie: Part 2,” Law 360.
“Tax Perspectives On Kisor V. Wilkie: Part 1,” Law 360.
“Indiana Supreme Court Cites Business Purpose Requirement in Holding RV Dealership Liable for Uncollected Sales Tax,” Salt Shaker.
“The Texas R&D Credit: Comptroller’s Regs Could Hogtie Taxpayers,” State Tax Notes (Cover).
“Highlights from the 2022 Texas Comptroller’s Annual Briefing,” Salt Shaker.
“The Year That Left Us SALT-y: Key State and Local Tax Developments in 2020,” Tax Executives Institute (TEI) Magazine.
“Destined for the Courtroom—Illinois Audit Program Won’t Stop Sales Tax Litigation,” Bloomberg Tax.
“Maryland’s Proposed Digital Advertising Tax (HB 732) – Insights and Analysis,” Salt Shaker.
“Ownership of Tennessee Mortgages Does Not Create Nexus for Foreign Investment Fund,” Salt Shaker.
“Louisiana Loses Jeopardy!,” Salt Shaker.
“Tough cheese: Wisconsin Tax Appeals Commission clarifies the scope of property tax manufacturing exemption,” Salt Shaker.
“Trouble at the Pump: Indiana Department of Revenue Concludes that a Holding Company is not Unitary with a Gas Station Partnership,” Salt Shaker.
“California’s Flawed Proposal to Expand False Claims Act to Tax,” Tax Notes.
“The Long Road to Clarity: FTB Holds Latest Meeting in Multiyear Project to Clarify Alternative Apportionment Petition Process,” Salt Shaker.
“Hearing Held on Controversial California Corporate Tax Disclosure Bill,” Salt Shaker.
“New Mississippi Marketplace Facilitator Law Leaves Food Delivery Services off the Menu,” Salt Shaker.
“Georgia DOR Rules that Sales Tax does not Apply to Most of Taxpayer’s Healthcare Document Management Services,” Salt Shaker.
“Maine Takes a Jumbo Slice of Taxpayer’s $3.6 billion Frozen Pizza Business Sale,” Salt Shaker.
“Michigan Supreme Court Rules Service Revenues Must be Sourced to the Location where the Services are Performed for City Income Tax Purposes,” Salt Shaker.
“Md. Digital Ad Tax Likely To Share Fate With Wash. Bank Tax,” Law360.
“California Court of Appeal holds that taxpayer must pay up before challenging a tax regulation’s validity,” Salt Shaker.
“If Md.’s Digital Ad Tax Is Passed, Court Challenges Will Follow,” Law 360.
“Inside California’s Office of Tax Appeals,” Eversheds Sutherland.
“California Tax Appeals Office Shows Impartiality In Its 1st Years,” Law360.
“Big Changes Proposed for Maryland Opportunity Zones,” Tax Notes.
“South Carolina Gets SaaS-y, Taxes Software Subscription Services,” Salt Shaker.
“Important Considerations from the MTC’s Draft 2019 Marketplace Facilitator White Paper,” Salt Shaker.
“Legal Alert: MTC Uniformity Committee considers updated marketplace facilitator white paper,” Eversheds Sutherland.
“Marketplace Monday: To Be or Not To Be A Seller,” Salt Shaker.
“How States Protect Marketplace Facilitators from Tax Overcollection Lawsuits,” Salt Shaker.
“Why a taxpayer’s carbon reactivation process is ineligible for Texas’ manufacturing sales tax exemption,” Salt Shaker.
“Marketplace Monday: You Might Be A Marketplace If…,” Salt Shaker.
“Get Your Refunds: New Jersey’s Alternative Minimum Tax Preempted by P.L. 86-272, Tax Court Says,” Salt Shaker.
“4 State Responses To Opportunity Zones,” Law 360.
“New York Disregards Taxpayer’s Reliance on Disregarded Entity Rules,” Salt Shaker.
“Tax Perspectives On Kisor V. Wilkie: Part 2,” Law 360.
“Tax Perspectives On Kisor V. Wilkie: Part 1,” Law 360.
“Indiana Supreme Court Cites Business Purpose Requirement in Holding RV Dealership Liable for Uncollected Sales Tax,” Salt Shaker.