Stephen P. Kranz Stephen P. Kranz

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Stephen (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 P. Kranz's full bio.

US Treasury Issues Guidance on the ARPA Claw-Back Provision


By , and on May 12, 2021
Posted In Constitutional Issues, Franchise Tax, Income Tax, Insurance Tax, Local Tax, Nationwide Importance, Property Tax, Sales Tax, Tax Base, Transaction Taxes

Earlier this week, the US Department of the Treasury (Treasury) issued formal guidance regarding the administration of the American Rescue Plan Act of 2021 (ARPA) claw-back provision. The guidance (Interim Final Rule) provides that the claw-back provision is triggered when there is a reduction in net tax revenue caused by changes in law, regulation or...

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Kansas Decouples from GILTI and 163j


By and on May 4, 2021
Posted In Federal Tax, Income Tax, Kansas, Tax Base

Yesterday afternoon the Kansas legislature overrode Governor Laura Kelly’s veto of Senate Bill (SB) 50, effectively enacting the provisions of the bill into law. Among those are provisions decoupling from certain Tax Cuts and Jobs Act (TCJA) provisions that taxpayers have been advocating for since 2018. Under the new law, for tax years beginning after...

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The US Department of the Treasury Says State IRC Conformity Bills Do Not Trigger Federal Relief Claw-Back Provision


By , and on Apr 9, 2021
Posted In Constitutional Issues, Franchise Tax, Gross Receipts Tax, Income Tax, Insurance Tax, Local Tax, Nationwide Importance, Property Tax, Sales Tax, Tax Base, Transaction Taxes

As we’ve blogged about in the past, the recently enacted American Rescue Plan Act of 2021 (ARPA) includes an ambiguous claw-back provision. If broadly interpreted, it could result in states losing relief funding provided under the APRA if there is any state legislative or administrative change that results in the reduction of state revenue. This...

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McDermott Provides Treasury Department with Concrete Suggestions for Guidance on the American Rescue Plan Act’s Claw-Back Provision


By , and on Mar 25, 2021
Posted In Constitutional Issues, Franchise Tax, Gross Receipts Tax, Income Tax, Insurance Tax, Local Tax, Nationwide Importance, Property Tax, Sales Tax, Tax Base, Transaction Taxes

The recently enacted American Rescue Plan Act of 2021 (ARPA) includes an ambiguous claw-back provision that has brought the world of state and local tax policymaking to a grinding halt. Because ARPA’s adoption occurred during the final weeks of many states’ legislative sessions, rapid issuance of guidance from the US Department of the Treasury is...

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Federal COVID-19 Relief Bill Brings State Tax Policy to a Grinding Halt


By , and on Mar 16, 2021
Posted In Constitutional Issues, Franchise Tax, Incentives, Income Tax, Local Tax, Nationwide Importance, Property Tax, Sales Tax, Tax Base

On March 11, 2021, US President Joe Biden signed the American Rescue Plan Act of 2021 (ARPA), the COVID-19 relief bill that includes $350 billion in relief to states and localities. To prevent states from using federal relief funds to finance tax cuts, Congress included a clawback provision requiring that any relief funds used to...

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False Claims Act Risk for Unclaimed Property Holders


By , and on Mar 15, 2021
Posted In False Claims Act, Nationwide Importance

In what has become an unfortunate trend, unclaimed property holders continue to be subject to lawsuits under state false claims acts (FCA – also called a qui tam or whistleblower action) for alleged underreporting and remittance of unclaimed property obligations. More than 30 states have a false claims act with whistleblower provisions and nearly all...

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Maryland Digital Advertising Services Tax—Implementation Delay Likely


By , and on Mar 2, 2021
Posted In Allocation/Appointment, Constitutional Issues, Maryland, Nationwide Importance

On the morning of Friday, February 26, 2021, the Maryland Senate Budget and Taxation Committee added a new item to its agenda for the hearing later that morning. The new item was proposed amendments to Senate Bill 787, a bill that would amend the Maryland Digital Advertising Tax by excluding broadcasters and news media and...

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Maryland Sued over Digital Advertising “Tax”


By and on Feb 18, 2021
Posted In Allocation/Appointment, Connecticut, Constitutional Issues, Maryland, Montana, Nationwide Importance, New York

Today, McDermott Will & Emery filed suit in Maryland federal court on behalf of a number of leading trade associations against Maryland Comptroller Peter Franchot, challenging the state’s recently enacted 10% gross receipts “tax” applicable to digital advertising revenue. The plaintiffs in the suit are the US Chamber of Commerce, the Internet Association, NetChoice and...

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Maryland Enacts First Digital Advertising Services Gross Receipts Tax: Now What?


By , and on Feb 12, 2021
Posted In Allocation/Appointment, Connecticut, Constitutional Issues, Indiana, Maryland, Montana, Nationwide Importance, New York, Oregon, Washington

General Assembly Veto Override On February 12, 2021, the Maryland General Assembly overrode Governor Larry Hogan’s veto of HB 732 (2020) (the Act), a bill enacting a first-of-its-kind digital advertising services tax on the annual gross receipts from the provision of digital advertising services in Maryland. The tax only applies to companies having annual gross...

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DC Council Expands False Claims Act to Tax Claims


By , and on Dec 1, 2020
Posted In District of Columbia, False Claims Act, Nationwide Importance

The DC Council has passed an amended bill (the False Claims Amendment Act of 2020, B23-0035) that beginning as early as January 2021 will allow tax-related false claims to be raised against large taxpayers for up to 10 years of prior tax periods! This troubling legislation creates a real and imminent possibility of prior tax...

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