In this episode of the SALT Shaker Podcast, host and SALT Counsel Jeremy Gove sits down with Partner Tim Gustafson to explore the historical evolution and current challenges surrounding California's sales factor.

The conversation traces California's apportionment journey from its original equally weighted three-factor formula to today's dominant single sales factor approach. Jeremy and Tim unpack key developments, including:

• California Supreme Court decisions shaping the definition of "gross receipts"
• A voter-approved initiative accelerating the shift to a single sales factor
• Regulatory amendments relating to market-based sourcing

The episode concludes with a discussion of a recent legislative change redefining "gross sales" as "net sales" – a retroactive adjustment now facing legal challenges for its conflict with prior judicial interpretations.

Plus, don't miss the overrated/underrated segment, where Jeremy and Tim share their hot takes on card games.

For a deeper dive into this topic, check out Tim's article, published in Tax Notes State, which he co-wrote with Associate Constance Chien.