Recent state court decisions are reshaping how states source receipts for income, franchise, and gross receipts tax purposes—particularly for businesses that sell through intermediaries. For consumer products and retail companies, these developments reflect a growing judicial focus on “ultimate destination” sourcing: where goods ultimately end up in the hands of the customer.

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Breen M. Schiller is a nationally recognized state and local tax (SALT) attorney with deep experience in SALT planning, audit defense, and complex litigation across multiple tax types, including income, franchise, gross receipts-based taxes, and sales/use taxes, on a multistate basis. She advises

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Breen M. Schiller is a nationally recognized state and local tax (SALT) attorney with deep experience in SALT planning, audit defense, and complex litigation across multiple tax types, including income, franchise, gross receipts-based taxes, and sales/use taxes, on a multistate basis. She advises a wide range of clients, from privately held mid-size businesses to multinational Fortune 100 corporations, on strategic and practical tax planning and dispute resolution.

Breen’s practice spans a broad spectrum of SALT issues, including nexus determinations, business/nonbusiness income classifications, apportionment and alternative apportionment methodologies, unitary business principles, combined reporting, federal change reporting, and credits and deductions. She also handles a variety of sales and use tax matters, such as exemption qualifications, inclusions and exclusions from the tax base, and issues related to digital products and cloud computing.

She has represented taxpayers at all levels of state and local tax controversy – from administrative proceedings to appellate court arguments – and has wide-ranging experience with audit defense, negotiated settlements, refund claims, and compliance matters. Leveraging her credibility with state departments of revenue, Breen has helped clients secure refunds and obtain key rulings, as well as secure proactive resolutions to matters.

Practicing nationwide, Breen regularly advises companies in the transportation, hospitality, manufacturing, retail, and oil and gas sectors. She has managed high-volume, multijurisdictional tax litigation while simultaneously developing proactive strategies to address multistate compliance for both income and sales/use taxes. Her approach is holistic and client-focused, shaped by her 15 years in private practice and leadership roles at top law firms. Prior to joining the firm, Breen was a Principal in EY’s National Tax Group.

Breen is a national thought leader on state tax issues and is deeply engaged in the SALT community. She co-founded Women in SALT, a group dedicated to connecting female SALT practitioners and fostering a collegial, collaborative network. She also serves on several advisory boards, including the Bloomberg State Tax Advisory Board, the Journal of State Taxation Editorial Board, the Paul J. Hartman Advisory Board, and the board of trustees for the Taxpayers’ Federation of Illinois. A frequent lecturer and contributor to major SALT organizations and publications, Breen is known for her insightful analysis of evolving tax policies and their implications for businesses operating across multiple jurisdictions.

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