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.
D.C. Bill Ostensibly Lowers Tax on Capital Gains from QHTC Investments… But How?
By Diann Smith, Eric D. Carstens and Stephen P. Kranz on Oct 9, 2014
Posted In Allocation/Apportionment, District of Columbia, Income Tax, Nationwide Importance, Tax Base
On September 23, District of Columbia Council Chairman Mendelson introduced the Promoting Economic Growth and Job Creation Through Technology Act of 2014 (Bill 20-0945 , hereinafter the “Act”) at the request of Mayor Vincent Gray. This marks the second time that the Council has considered the introduced language; it was originally included as part of the...
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Multistate Taxpayers Take Note! Recap of the First Day of the MTC Pricing Summit
By Diann Smith and Stephen P. Kranz on Oct 7, 2014
Posted In Income Tax, Nationwide Importance, Transfer Pricing
On October 6, 2014, the Multistate Tax Commission (MTC) held the first day of a two-day meeting intended to educate state revenue authorities on corporate income tax issues surrounding intercompany transactions, and further refine a path forward for states interested in collaborating on audit and compliance strategies. This first day focused entirely on presentations by...
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Did You Pay a Michigan Assessment After an MTC Audit? What the State’s Retroactive Compact Repeal May Mean
By Diann Smith and Stephen P. Kranz on Sep 30, 2014
Posted In Income Tax, Michigan, Minnesota, Nationwide Importance, Sales Tax, UDITPA
On September 11, 2014, Michigan Governor Rick Snyder signed legislation (SB 156) retroactively repealing the Multistate Tax Compact (Compact, formerly codified at MCL § 205.581 et seq.) from the state statutes, effective January 1, 2008. Among other things, the bill’s passage ostensibly supersedes the Michigan Supreme Court’s decision in Int’l Bus. Machines Corp. v. Dep’t...
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Can Taxpayers Find an Advantage in Vodafone Nowhere Income Argument?
By Diann Smith, Eric D. Carstens and Stephen P. Kranz on Sep 29, 2014
Posted In Allocation/Apportionment, Tennessee, UDITPA
It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900 (Tenn. Ct. App. June 23, 2014). In this much discussed case, the Tennessee Court of Appeals affirmed a variance from the statutory cost of...
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MTC to Hold Transfer Pricing Group Meeting with Third-Party Contract Auditors
By Diann Smith and Stephen P. Kranz on Sep 23, 2014
Posted In Alabama, District of Columbia, Florida, Georgia, Hawaii, Income Tax, Iowa, Kentucky, Nationwide Importance, New Jersey, North Carolina, Transfer Pricing
On October 6 and 7, 2014, the Multistate Tax Commission (MTC) will hold an Arm’s-Length Adjustment Service (ALAS) Advisory Group Conference at the Atlanta Airport Marriott. On the first day, third-party contract auditors will give presentations on transfer pricing issues. An ALAS Advisory Group meeting will be held on the second day. This past year,...
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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...
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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...
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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...
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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...
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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...
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