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.
Gross Receipts Taxes Face Policy and Legal Challenges
By Diann Smith and Stephen P. Kranz on Sep 24, 2019
Posted In Constitutional Issues, Gross Receipts Tax, Local Tax, Nationwide Importance
“Generally, the only places with gross receipts taxes today are U.S. states and developing countries.” –Professor Richard Pomp, University of Connecticut As the economy shifts to a digital one, we are finding that states are turning toward unconventional revenue options. One trend we’re seeing is the surprising comeback of the gross receipts tax (GRT): Oregon’s...
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Vultures Circling as Bill to Expand California FCA to Tax Looms in Legislature
By Charles Moll, III, Diann Smith, Stephen P. Kranz and Troy M. Van Dongen on Aug 26, 2019
Posted In California, False Claims Act, Interest and Penalties, Nationwide Importance, Procedure
Legislators in Sacramento are mulling over one of the most (if not the most) troubling state and local tax bills of the past decade. AB 1270, introduced earlier this year and passed by the Assembly in late May, would amend the California False Claims Act (CFCA) to remove the “tax bar,” a prohibition that exists...
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BREAKING NEWS: New Jersey Is GILTI, Again!
By Stephen P. Kranz on Aug 23, 2019
Posted In Federal Tax, Income Tax, New Jersey, Tax Base
Taxpayers may have celebrated too soon when the New Jersey Division of Taxation announced that it was withdrawing TB-85 and the GDP-based apportionment regime for global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII) in favor of a more fair apportionment regime. Read our first post on T8-85 here. Yesterday, the Division issued a...
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BREAKING NEWS: New Jersey Is Not GILTI! The Division Withdraws TB-85
By Stephen P. Kranz on Aug 20, 2019
Posted In Federal Tax, Income Tax, Tax Base
Many New Jersey taxpayers have a reason to celebrate today as the Division of Taxation withdrew Technical Bulletin-85, providing for a special apportionment regime for global intangible low-taxed income (GILTI) and income used to compute the foreign-derived intangible income (FDII) deduction that many felt was unfair and potentially unconstitutional. In December 2018, the New Jersey...
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Batten Down the Hatches: Digital Tax Nor’easter Coming This Fall
By Eric D. Carstens, Mark Nebergall and Stephen P. Kranz on Jun 28, 2019
Posted In Connecticut, Rhode Island, Sales Tax, Tax Base
Recently passed budget legislation in both Connecticut and Rhode Island included tax increases on sales of digital goods and services. The Connecticut bill has been signed into law. The Rhode Island bill passed late last night awaits executive action. Below are brief summaries of the impacts of these bills on the sales taxation of digital...
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Wisconsin Enacts Discriminatory Exit Charge for Businesses Moving out of State
By Mark Nebergall and Stephen P. Kranz on Jun 28, 2019
Posted In Constitutional Issues, Income Tax, Tax Base
On June 24, 2019, Wisconsin Governor Tony Evers (D), signed into law AB 10, entitled “2019 Wisconsin Act 7.” This Act either bars a deduction for, or requires that amounts deducted be added back to, Wisconsin taxable income “for moving expenses” deducted on federal income tax returns if the expenses are associated with a move...
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BREAKING NEWS: More States Opt Not to Tax GILTI
By Stephen P. Kranz on Jun 27, 2019
Posted In Florida, Income Tax, New York, Oregon, Tax Base
This has been an eventful and exciting week for those interested in the states’ taxation of global intangible low-taxed income (GILTI). On Monday, taxpayers received the good news that New York Governor Cuomo signed S. 6615—a bill that excludes 95% of GILTI from the New York State corporate income tax base. By passing this bill,...
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Kentucky to Begin Taxing Video Streaming Services under Telecom Tax
By Eric D. Carstens, Mark Nebergall and Stephen P. Kranz on May 24, 2019
Posted In Kentucky, Sales Tax, Tax Base, Transaction Taxes
Legislators in Frankfort added a new “video streaming service” tax to the omnibus tax bill (HB 354) as part of a closed-door conference committee process before the bill was hastily passed in the House and Senate. Notably, the new video streaming service tax was not previously raised or discussed as part of HB 354 (or...
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Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base
By Stephen P. Kranz on May 15, 2019
Posted In Constitutional Issues, Income Tax, Tax Base, Tennessee
On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base for tax years beginning on or after January 1, 2018. By enacting this bill, Tennessee joins about...
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An Uneven Playing Field: Judicial Deference to State Tax Administrator Interpretations
By Diann Smith, Mark Nebergall and Stephen P. Kranz on May 14, 2019
Posted In Audits, Constitutional Issues, Income Tax, Local Tax, Nationwide Importance, Sales Tax
Judicial deference to state tax agencies puts taxpayers at a steep disadvantage and wastes time and resources on costly tax disputes. A united advocacy effort can help promote passage of state-level legislation that takes the tax administrator’s thumb off the scales of justice in administrative and judicial review of tax determinations. Access the full article....
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