Chris is a partner and Chair of the State and Local Tax (SALT) group. He focuses his practice on resolving complex SALT issues and regulatory compliance matters.
Chris represents multistate and multinational companies on a range of issues, including income tax, local taxes, sales and use taxes, and taxes relating to financial institutions, insurance, telecommunications and energy companies. He has successfully represented clients at all state court levels and before administrative tribunals, nationwide.
An active member of the SALT community, Chris is a regular lecturer and author to many major SALT institutions and their publications. He currently serves as vice chair on the committee for IPT’s Annual Conference Income Tax Section and previously worked at COST as a legal fellow.
Detailed Counsel, Always Up-to-Date
Clients rely on Chris for his sophisticated understanding of their multistate tax issues. A frequent author and lecturer, Chris is a go-to resource for many industry publications and his clients alike. While he loves learning about his clients’ businesses to better help with multistate compliance, businesses often come to Chris for his litigation experience. When the stakes are the highest, Chris’s experience and enthusiasm give clients the peace of mind to confidently resolve their issues with any state.
The George Washington University Law School, J.D., with honors
Vassar College, B.A. in Environmental Science
Christopher T. Lutz Discusses Localities Outsourcing Tax Services with Law360.
Chris Lutz shared his insight into online merchants' requirement to pay income tax in additional states with Bloomberg Law as states consider how to implement some or all of a statement on Public Law 86-272, recently revised by the Multistate Tax Commission.
In "PepsiCo Unitary Group Includes Member, Illinois Tribunal Says" Chris T. Lutz discusses the ruling with State Tax Notes. Read the full article by State Tax Notes here. The Illinois Tax Tribunal ruled that a member of PepsiCo’s business group is a company conducting business within the United States, and its income is included in the unitary group’s income. The…
In this article by State Tax Notes, Chris T. Lutz discusses P.L. 86-272's role in the modern economy. Download the full article here. During a March 17, 2021 panel of the American Bar Association/Institute for Professionals in Taxation virtual seminar on income tax, Chris wondered about the timing of the work group starting a few months after the 2018 South…
Chicago, IL September 10, 2020 HMB Legal Counsel, a preeminent provider of legal services announced Chris T. Lutz as the Practice Chair for the State and Local Tax Group. As a practice group leader, Chris will oversee coaching, planning, economic oversight, positioning and recruitment for his group. Practice group leadership transitions are part of HMB's planning and leadership strategy, designed…
Marilyn Wethekam, Jordan Goodman and Chris Lutz present, "Notes from the Courtroom: An Update on State Corporate Income Tax Litigation Across the Country."
Upcoming Webinar: Chris T. Lutz Presents, “State Taxation of Digital Goods, Services and Software in 2021” with Duff and Phelps.
4/21/21 1:45PM The TEI Dallas Chapter have asked Jordan M. Goodman and Chris T. Lutz to take a tour of the countries’ state tax decisions and explain their impact on multi-state business. They will also identify trends around the country in the SALT area and offer advice on how to address state audit positions.…
3/17/21 Chris T. Lutz and David A. Hughes will be presenting and moderating at the ABA-IPT conference for webinar titled, “What to do with Public Law 86-272?” Public Law 86-272 is now 60 years old. While P.L. 86-272 made sense in the pre-internet, manufacturing oriented economy of 1959, many commentators have called into question the law’s continuing relevance in a…
3/11/21 12:00PM - 1:00PM CT In this presentation, HMB’s Chris Lutz and Jordan Goodman will square off in the Zoom arena to determine who is the heavy-weight champion of all things SALT! Join us for a wide-ranging debate covering all corners of the state and local tax landscape including: Nexus for all taxes; Taxability of software; Developments in apportionment; and…
Effective January 1, 2021 Kentucky eliminated its Bank Franchise Tax ("BFT")and instead subjected financial institutions and financial organizations to the state's existing Corporate Income Tax ("CIT") and Limited Liability Entity Tax ("LLET").
Read the full article on State Tax Notes here (subscription required). In his new column on State Tax Notes, Chris discusses how states and Congress should address challenges presented by Public Law 86-272 and criticizes state efforts to interpret the law out of existence. In the past 15 years, the state corporate income tax landscape has undergone significant change. Although…
With the Tax Cuts and Jobs Act (TCJA), many taxpayers have begun to focus on the manner in which states tax foreign income. Illinois? taxation of foreign income is fairly in line with most other states. However, given how much states can diverge on this complicated issue, having a general understanding of how the state treats foreign income is necessary for any multinational business operating in Illinois.
In a previous post, we addressed the basics of Illinois corporate income tax apportionment. We also addressed how while most corporations are required to follow the standard statutory formula, the state imposes unique rules on a number of industries, including financial organizations. In addition to financial organization, insurance companies must also apportion their income to Illinois according to special rules. As with financial organizations, beginning with the tax year ending December 31, 2017, insurance companies must be included in the combined return with the entire unitary business group.
In a General Information Letter published in 2017, Illinois addressed how its taxation of canned and custom software would apply to cloud computing. The state explained that software as a service (SaaS) is not subject to the Retailers' Occupation Tax, and SaaS providers are instead subject to the Servicemen Occupation Tax. Thus, providers of SaaS to Illinois customers will generally be subject to use tax on tangible personal property transferred as an incident to the sale of SaaS.
Partnerships are not subject to the Illinois Income Tax. Instead, partners are taxed individually on their distributive shares from a partnership. For nonresident individual partners, only their pro rata share of the partnership's income apportioned to Illinois is taxable. Corporate partners may be required to combine the partnership income and factors in their combined business income and factors if they are unitary with the partnership. However, it is always important to keep in mind that Illinois also imposes a Replacement Tax which is generally imposed at the entity level.
The Illinois Franchise Tax is a weird tax. It is imposed on the privilege of exercising a franchise in Illinois or, in the case of foreign corporations, for the authority to transact business in the state. It is administered by the Illinois Secretary of State, not the Department of Revenue, and is measured by paid-in capital. Knowing the ins and outs of the Franchise Tax is a must for any corporation doing business in the state.