Samantha K. Breslow Partner
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  • F 312.267.2226
Samantha K. Breslow

Sam is a Partner in 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


  • Illinois


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

Professional Memberships

  • Illinois State Bar Association, Chair of the State and Local Tax Council
  • Chicago Tax Club, Board of Directors and Chair of the Administration Committee
  • Chicago Bar Association, Former Chair of State and Local Tax Committee
  • National Association of State Bar Tax Sections (NASBTS), Executive Committee




  • 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…


  • California Franchise Tax Board to Share Unclaimed Property Information with State ControllerJanuary 31, 2022

    Effective January 1, 2022, the California Franchise Tax Board (“FTB”) has the authority under Assembly Bill 466 to share information with the State Controller’s Office (“SCO”) relating to a taxpayer’s compliance with the California’s unclaimed property laws. To gather this information, the FTB has added a few questions to California’s business entity tax returns for tax year 2021, including whether…

  • 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.

  • University of Illinois College of Law, J.D., magna cum laude
  • The University of Texas, B.A. in English and Spanish, University Honors
  • Illinois
500 West Madison Suite 3700
Chicago IL 60661

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