Stephen P. Kranz
Subscribe to Stephen P. Kranz's PostsStephen (Steve) P. Kranz is a tax lawyer who solves tax problems differently. Over the course of his extensive career, Steve has acquired specific skills and developed a unique approach that helps clients develop and implement holistic solutions to all varieties of tax problems. He combines strategic thinking with effective skills for the courtroom, the statehouse and the conference room. Read Stephen Kranz's full bio.
California Legislator Considers Digital Advertising Tax
By Stephen P. Kranz, Michael J. Hilkin, Mark Nebergall and Jonathan C. Hague on Mar 29, 2024
Posted In Allocation/Apportionment, California, Constitutional Issues, Nationwide Importance, Sales Tax, Tax Base, Transaction Taxes
Senator Steven Glazer, chair of the California State Senate Revenue and Tax Committee, is treating data like the next gold rush and taking bold steps to mine this new vein of wealth with his proposed “Digital Data Extraction Tax Law.” While couched as a tax on “data extraction,” the base for the tax is digital...
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Microsoft Scores Massive Win in California, Opens the Door for Others Nationwide
By Stephen P. Kranz, Diann Smith and David Jasphy on Mar 15, 2024
Posted In Allocation/Apportionment, California, Federal Tax, Income Tax, Nationwide Importance, Tax Base
The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also claimed a dividends received deduction (DRD). Microsoft filed a water’s-edge combined report for the years at issue and deducted...
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ALJ Rules That a Taxpayer Is a Qualified New York Manufacturer Even Though Qualifying Property Was Operated by a Third Party
By Stephen P. Kranz, Michael J. Hilkin and David Jasphy on Mar 4, 2024
Posted In Incentives, Income Tax, New York
The New York State Division of Tax Appeals determined that E. & J. Gallo Winery is a qualified New York manufacturer (QNYM) even though its only property in New York that could allow it to qualify for QNYM classification – a vineyard – was operated by a third-party contractor and Gallo did not have any...
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New Jersey Governor Flip-Flops on Corporate Business Tax Surtax Expiration
By Stephen P. Kranz, Michael J. Hilkin and David Jasphy on Feb 27, 2024
Posted In Income Tax, New Jersey
After months of insisting that he would not allow New Jersey’s 2.5% corporate business tax surtax to be extended – and previously having allowed it to lapse for tax years beginning on January 1, 2024 – New Jersey Governor Phil Murphy is now proposing that the surtax be revived for companies earning profits that exceed...
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Vermont Considers Imposing Mandatory Worldwide Combined Reporting
By Stephen P. Kranz, Michael J. Hilkin and David Jasphy on Feb 2, 2024
Posted In Federal Tax, Income Tax, Local Tax, Nationwide Importance, Tax Base, Unitary Business, Vermont
The Vermont House Committee on Ways and Means is actively exploring a proposal to become the first state to enact mandatory worldwide combined reporting for corporate income tax purposes. While legislation has not been formally proposed, the Committee has examined a working draft that could be embedded into a broader tax legislation package. In Committee...
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Following Maryland’s Lead? We Guess Everyone Wants to Go to Court. Icy Challenges to Nebraska’s Advertising Services Tax Act Start to Emerge
By Stephen P. Kranz, Mark Nebergall and Jonathan C. Hague on Jan 18, 2024
Posted In Constitutional Issues, Nationwide Importance, Nebraska, Sales Tax, Tax Base
Nebraska Governor Jim Pillen’s ambitious plan to provide $2 billion in property tax relief via an increase in the sales tax rate and an expansion of the sales tax base is stirring significant debate. Part of his proposal is embodied in the newly introduced Legislative Bills 1310 and 1354, known as the “Advertising Services Tax...
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New York Formally Adopts Corporate Tax Reform Regulations
By Stephen P. Kranz, Richard C. Call, Michael J. Hilkin and David Jasphy on Dec 28, 2023
Posted In New York
On December 27, 2023, the New York State Department of Taxation and Finance (Department) adopted corporate tax reform regulations addressing New York’s corporate tax reform effective in 2015. The adopted regulations are consistent with the proposed regulations released in August 2023 and only include what the Department has called “minor clarifying and technical changes.” Although...
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Action Required: Maryland Denies All Ad Tax Refund Claims
By Stephen P. Kranz, Eric D. Carstens and Mark Nebergall on Oct 27, 2023
Posted In Maryland, Nationwide Importance, Procedure
The Maryland Comptroller appears to have denied all refund claims for the 2022 digital advertising gross revenues (DAGR) tax! The denial notices were seemingly dated on or around October 11, 2023, and were sent via certified mail two weeks ago. The denial notices require immediate action by taxpayers. Read more here.
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Massachusetts Adopts Single-Sales-Factor Apportionment; Manufacturing Classification Becomes Less Controversial
By Stephen P. Kranz, Richard C. Call and David Jasphy on Oct 11, 2023
Posted In Allocation/Apportionment, Massachusetts
On October 4, 2023, Massachusetts Governor Maura Healey signed House Bill 4104 into law. The most significant change it introduces is the adoption of single-sales-factor apportionment (SSF) for all corporate taxpayers, not just manufacturers and mutual fund service corporations. Massachusetts joins more than 30 other states that have adopted either mandatory or elective SSF. The...
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Texas Taxing 130% of Marketplace Sales
By Stephen P. Kranz, Mark Nebergall and Eric D. Carstens on Oct 3, 2023
Posted In Audits, Nationwide Importance, Sales Tax, Texas, Transaction Taxes
Proving that everything is bigger in Texas, the state’s Comptroller is now assessing marketplace providers on 130% of their sales. It seems a sales tax on 100% was not big enough for tax officials in the Lone Star State. The additional 30% is a tax on the portion of the product sales price kept by...
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