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.
Connecticut Hires Chainbridge Software LLC for Transfer Pricing Training
By Diann Smith and Stephen P. Kranz on Aug 21, 2014
Posted In Connecticut, Income Tax, Nationwide Importance, Tax Base, Transfer Pricing
On July 15, 2014, the Connecticut Department of Revenue Services awarded Chainbridge Software LLC a contract worth $50,000 for on-site and remotely supported training for transfer pricing audits. Chainbridge is infamous for being the contract auditor hired by the District of Columbia Office of Tax and Revenue to manufacture transfer pricing-based assessments. In 2012, the...
Continue Reading
Is 2015 the Beginning of Mandatory Single Sales Factor Apportionment for D.C. Taxpayers?
By Diann Smith and Stephen P. Kranz on Aug 13, 2014
Posted In Allocation/Apportionment, Constitutional Issues, District of Columbia, Income Tax, Local Tax, UDITPA
On July 14, 2014, the Fiscal Year 2015 Budget Support Emergency Act of 2014 (2015 BSEA) was enacted after the D.C. Council voted to override Mayor Vincent Gray’s veto. The act includes a tax relief package recommended by the D.C. Tax Revision Commission, and includes a change to D.C.’s apportionment formula, moving the city to...
Continue Reading
Idaho Drafting Cloud Computing Regulation in the Wake of H.B. 598
By Stephen P. Kranz on Aug 11, 2014
Posted In Idaho, Sales Tax, Tax Base, Transaction Taxes
The Idaho Sales Tax Rules Committee is currently revising Rule 027, Computer Equipment, Software, and Data Services, in response to the passage of H.B. 598. The Committee met for the last time on July 24 to discuss the draft rule prior to the promulgation of the proposed rule. As previously discussed in Inside SALT, the...
Continue Reading
Was It Wirth It? The Pennsylvania Supreme Court Sets a Low Bar for Minimum Contacts
By Diann Smith and Stephen P. Kranz on Jul 28, 2014
Posted In Constitutional Issues, Income Tax, Nexus, Pennsylvania
In Wirth v. Commonwealth, the Supreme Court of Pennsylvania held that Pennsylvania personal income tax applied to non-resident limited partners whose only connection with the state was the ownership of a small interest in a partnership that owned Pennsylvania property. This ruling has weakened the effectiveness of the Due Process Clause as a defense against...
Continue Reading
Allied Domecq: Nexus-Combined Reporting
By Diann Smith and Stephen P. Kranz on Jul 16, 2014
Posted In Constitutional Issues, Income Tax, Massachusetts, Nexus
In Allied Domecq Spirits & Wines USA, Inc. v. Commissioner of Revenue, the Massachusetts Court of Appeals held that the parent company of a Massachusetts taxpayer could not be included in the taxpayer’s Massachusetts nexus-combined returns because the parent’s nexus with Massachusetts was a sham. Regardless of the validity of the parent’s presence in the...
Continue Reading
State and Local Tax Supreme Court Update: June 2014
By Diann Smith and Stephen P. Kranz on Jun 25, 2014
Posted In Alabama, Allocation/Apportionment, Colorado, Constitutional Issues, Income Tax, Local Tax, Mississippi, Nationwide Importance, Sales Tax, Transaction Taxes
On June 10, 2014, the Supreme Court of the United States distributed three state and local tax cases for a conference to be held on June 26, 2014: Equifax, Inc. v. Mississippi Department of Revenue, Direct Marketing Association v. Brohl, and Alabama Department of Revenue v. CSX Transportation, Inc. The Supreme Court previously agreed to...
Continue Reading
Louisiana Taxpayers Beware Non-Uniform Sales Tax Treatment
By Stephen P. Kranz on Jun 25, 2014
Posted In Local Tax, Sales Tax, Tax Base
On June 11, 2014, the Louisiana 24th Judicial District Court held in Normand v. Cox Communications Louisiana, LLC that video-on-demand and pay-per-view programming were not subject to Jefferson Parish sales tax because they were not tangible personal property, but non-taxable services. Prior to this case, the taxability of pay-per-view and video-on-demand programming within the local...
Continue Reading
You Do the Math: Unclaimed Property Lawsuit Filed Against Kelmar
By Diann Smith, Eric D. Carstens and Stephen P. Kranz on Jun 9, 2014
Posted In Constitutional Issues, Delaware, Nationwide Importance, Unclaimed Property
Mark McQuillen, president of Kelmar Associates, LLC, was misinformed when he was quoted as saying “I’ve never been sued” on May 26—less than one week after suit was filed against Kelmar and three Delaware state officials in a Delaware Federal District Court. See 72 State Tax Notes 455 (May 26, 2014). While the timing of...
Continue Reading
2015 D.C. Budget Bill Includes Several Significant Business Tax Changes
By Diann Smith, Eric D. Carstens and Stephen P. Kranz on May 21, 2014
Posted In Allocation/Apportionment, District of Columbia, Income Tax, UDITPA
The FY 2015 District of Columbia Budget Request Act (BRA, Bill 20-749) is currently being reviewed by the D.C. Council after being introduced on April 3 at the request of Mayor Vincent Gray. This year’s Budget Support Act (BSA, Bill 20-750), the supplementary bill implementing changes based on the BRA, contains several significant modifications to...
Continue Reading
An End to the Madness? Delaware Bill Introduced to End Contingent Fee Unclaimed Property Audits
By McDermott Will & Emery, Diann Smith and Stephen P. Kranz on May 20, 2014
Posted In Delaware, Unclaimed Property
Any holder who has been involved in an unclaimed property audit has experienced frustration when dealing with third party contingent fee auditors. Delaware’s increasing aggressiveness in collecting unclaimed property has been inextricably tied to the use of these auditors, who are known for taking liberties with unclaimed property laws, harassing holders and inflating the values...
Continue Reading
