Jennifer Karpchuk
Partner

Overview
Jennifer W. Karpchuk is a tax attorney in Holland & Knight's Philadelphia office and co-chair of the State and Local Tax Team. Ms. Karpchuk represents companies and individuals in all aspects of state and local tax litigation, controversy, compliance and planning.
Ms. Karpchuk has extensive experience handling state and local tax matters involving corporate income taxes, franchise taxes, gross receipts taxes, personal income taxes, sales and use taxes, business privilege taxes and real estate taxes.
Ms. Karpchuk advises clients in all aspects of state and local tax compliance and litigation, including:
- challenging taxing authorities' determinations of nexus creating activities
- challenging taxing authorities' imposition of sales tax to evolving digital goods and services
- challenging audit determinations and assessments, as well as seeking refunds from state and local governments
- handling administrative appeals at the state and local levels, along with litigating unresolved disputes in state and local courts
- handling post-trial appeals at all appellate levels and reducing interest and penalties associated with past-due taxes through the use of state and local amnesty, voluntary disclosure programs and administrative appeals
- challenging property tax assessments, including valuation and lack of uniformity
In addition, Ms. Karpchuk handles transactional planning for clients and has experience in:
- determining nexus and potential nexus for sales and use tax, income tax and gross receipts tax purposes, as well as developing strategies to minimize exposure
- advising clients on the tax implications of pending and past transactions
- planning for and mitigating tax burdens
- maximizing available tax opportunities or credits
In addition to her legal practice, Ms. Karpchuk writes a quarterly article for Tax Notes State and is a frequent contributor to The Legal Intelligencer, Law360 and Bloomberg Tax. She is also co-author of The Legal Intelligencer's Pennsylvania Tax Handbook and the Pennsylvania chapter of the American Bar Association's Property Tax Deskbook.
Prior to joining Holland & Knight, Ms. Karpchuk served as the chair of the state and local tax practice for a tax-focused law firm in Philadelphia.
Representative Experience
- Represented multistate corporations in challenging states' attempt to invoke alternative apportionment
- Represented multistate corporations in challenging Pennsylvania's corporate net income add-back provision
- Represented multistate corporations in challenging states' cost of performance sourcing methodologies and market-based sourcing methodologies, including look-through/customer's challenges
- Represented multistate corporations in litigating whether they had a taxable nexus in the City of Philadelphia or the Commonwealth of Pennsylvania
- Successfully argued to the Pennsylvania Supreme Court that taxpayers were entitled to a credit on overpayments of estimated Philadelphia Business Privilege Tax, which resulted from adjustments made through a Revenue Agent Report pursuant to an IRS audit; the City of Philadelphia unsuccessfully argued that the three-year statute of limitations should apply both to refunds and to credits; ruling in the taxpayers' favor, the court accepted Ms. Karpchuk's argument that the statute only provided for a statute of limitations for refunds, not credits, and therefore the taxpayer was entitled to credits for the overpayments
- Successfully argued that a local Business Privilege Tax imposed on fees paid by Pennsylvania franchisees to an out-of-state company's regional office in the township was unconstitutional because it was not fairly apportioned; the court found that the township taxed all of the charges from franchise stores in Pennsylvania, even though the activity that generated the Pennsylvania charges resulted from economic activity from both inside and outside the state
Credentials
- Temple University, Beasley School of Law, J.D.
- University of Delaware, B.A., cum laude
- Pennsylvania
- New Jersey
- U.S. Supreme Court
- Philadelphia Bar Association, Tax Section, Chair 2025-2027; Vice Chair, 2024; Secretary-Treasurer, 2023; Tax Council, Elected Member, 2020-2022
- Pennsylvania Bar Association (PBA), Tax Section, Past Chair, 2022-2024; Vice Chair, 2020-2022; Secretary, 2018-2020
- American Bar Association (ABA), State and Local Taxes (SALT) Committee, Vice Chair, 2023-Present
- Philadelphia Tax Reform Commission, 2024-Present
- Philadelphia Tax Reform Working Group, 2021
- Rising Star, International Tax Review World Tax, Tax Controversy, 2025
- The Best Lawyers in America guide, Tax Law, 2021-2025; Women in the Law, Business Edition, 2021
- Chambers USA – America's Leading Business Lawyers guide, Tax, 2021-2024
- Rising Star, Pennsylvania Super Lawyers magazine, 2016-2019, 2021-2024
- The Legal 500 USA, Tax Controversy, 2023
- The Legal Intelligencer, Lawyer on the Fast Track, 2021
- Main Line Today, Top Lawyer in Tax, 2018-2019