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.
Maryland Ad Tax Denials Coming: Are You Ready for Tax Court?
By Stephen P. Kranz, Mark Nebergall and Eric D. Carstens on Sep 18, 2023
Posted In Maryland, Nationwide Importance, Procedure
Winter is coming, and so are denials of taxpayer refund claims for return of the illegally extracted Maryland digital ad tax (DAT). Sources in Annapolis report the Maryland Comptroller is preparing denial notices imminently. Taxpayers need to be prepared for quick action once that happens. According to our intelligence, the denial letters will inform recipients...
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At the 10-Yard Line: New York Formally Proposes Corporate Tax Reform Regulations
By Stephen P. Kranz, Richard C. Call, Michael J. Hilkin and David Jasphy on Aug 11, 2023
Posted In Allocation/Apportionment, Income Tax, Local Tax, Nationwide Importance, New York, Nexus, Unitary Business
On August 9, 2023, the New York State Department of Taxation and Finance (Department) released 417 pages of proposed regulations, an important step toward concluding a now almost decade-long process to implement corporate tax reform. The journey began in 2014 with the enactment of legislation modernizing the state’s corporate tax law. Thereafter, the Department released...
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As Minnesota Moves Toward GILTI Taxation, New Jersey May Be Moving Away from It
By Stephen P. Kranz, Michael J. Hilkin and Diann Smith on May 23, 2023
Posted In Allocation/Apportionment, Federal Tax, Income Tax, Minnesota, Nationwide Importance, New Jersey, Tax Base, Unitary Business
We previously reported that the Minnesota Legislature was considering imposing mandatory worldwide combined reporting through an omnibus tax bill. Subsequent to our report and in the face of numerous criticisms, Minnesota Senate leaders backed away from the proposal. But ominously, those same leaders said they would examine other tax increases to make up for the...
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Be Careful What You Wish For: Minnesota May Be on the Precipice of Enacting Worldwide Combined Reporting at the Worst Possible Time
By Stephen P. Kranz, Michael J. Hilkin and Diann Smith on May 4, 2023
Posted In Federal Tax, Income Tax, Local Tax, Minnesota, Nationwide Importance, Tax Base, Unitary Business
It has been widely reported that the Minnesota Legislature has advanced an omnibus tax bill that would require the inclusion of the “entire worldwide income” of combined corporate income tax filers engaging in a unitary business. Tax press outlets have made the broad claim that mandatory worldwide combined reporting will “add foreign subsidiaries’ profits” to...
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Massachusetts Department of Revenue Releases Guidance on a De Minimis Exception for Use Tax on Rolling Stock
By Richard C. Call, Stephen P. Kranz and Jonathan C. Hague on Mar 28, 2023
Posted In Audits, Local Tax, Massachusetts, Nationwide Importance, Sales Tax
The Massachusetts Department of Revenue (DOR) recently released Directive 23-1, which outlines the conditions for a de minimis exception where the Commissioner will not require a taxpayer to pay the use tax for rolling stock used or stored within the state. This directive comes at a time when the DOR is auditing many companies that...
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Meaningful Statute of Limitations for Unclaimed Property Audits and Enforcement Actions? Michigan Court of Appeals Says Yes!
By Eric D. Carstens, Stephen P. Kranz and Diann Smith on Mar 10, 2023
Posted In Audits, Michigan, Nationwide Importance, Procedure, Unclaimed Property
On January 19, 2023, the Michigan Court of Appeals affirmed two 2022 trial court orders, holding that initiating an unclaimed property audit does not toll (or freeze) the running of the statute of limitations (time-bar) for the Michigan State Treasurer to commence “an action or proceeding” with respect to a duty of a holder.[1] As...
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Pennsylvania Supreme Court Rules Coupon Amounts Are Not Subtracted from Sales Tax Base Unless Sales Receipt Adequately Describes Taxable Item and Coupon
By Stephen P. Kranz and Michael J. Hilkin on Feb 24, 2023
Posted In Audits, Local Tax, Pennsylvania, Sales Tax, Tax Base, Transaction Taxes
Overturning a 6-1 en banc decision by the Pennsylvania Commonwealth Court, the Pennsylvania Supreme Court held that a coupon does not reduce the price upon which sales tax must be collected unless the coupon is adequately described and “linked” with the taxable item in accordance with Pennsylvania Department of Revenue (DOR) regulations. The case was...
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Tax That DC?!?! FCA Suit on Residency Brings Business Intelligence Company into the Crosshairs
By Eric D. Carstens, Stephen P. Kranz, Michael J. Hilkin and Diann Smith on Sep 2, 2022
Posted In Constitutional Issues, District of Columbia, False Claims Act, Income Tax, Local Tax, Nationwide Importance, Tax Base
For the first time since the enactment of the False Claims Amendment Act of 2020, the DC Attorney General’s (AG’s) Office has used its new tax enforcement powers to pursue an alleged personal income tax deficiency. This development brings to the forefront a long-simmering constitutional problem with DC’s statutory residency law and offers a stern...
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Fatally Flawed? Illinois Municipal League’s Model Streaming Subscription Tax
By Stephen P. Kranz, Mark Nebergall, Catherine A. Battin and Jonathan C. Hague on Aug 24, 2022
Posted In Illinois, Local Tax, Nationwide Importance
The Illinois Municipal League (IML) represents the interests of 219 home rule municipalities in Illinois.[1] The IML recently released a revised draft model, “Municipal Streaming Tax Ordinance,” (the model) for use by the home rule municipalities in imposing an “amusement tax” on, inter alia, music and video streaming services and online gaming.[2] If the subscriber’s...
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New Mexico Proposes Regulations Addressing Gross Receipts Tax Treatment of Digital Advertising Services
By Eric D. Carstens, Stephen P. Kranz, Michael J. Hilkin, Mark Nebergall and Jonathan C. Hague on Aug 11, 2022
Posted In Allocation/Apportionment, Constitutional Issues, Local Tax, Nationwide Importance, New Mexico, Sales Tax, Tax Base, Transaction Taxes
On August 9, 2022, the New Mexico Taxation and Revenue Department published proposed regulations addressing the gross receipts tax (New Mexico’s version of a sales tax) treatment of digital advertising services. The Department states the proposed regulations do not reflect a change in policy but instead ensure the rules are consistent for all advertising platforms....
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