Overview

Jennifer Karpchuk represents companies and individuals in state and local tax litigation, controversy, compliance and planning, helping clients challenge assessments, reduce exposure and capture available tax opportunities. Based in Philadelphia, she co-chairs Holland & Knight's State and Local Tax Team and handles matters involving corporate income, franchise, gross receipts, personal income, sales and use, business privilege and real estate taxes.

When disputes arise, Jennifer guides clients from audit through the highest levels of appeal. She challenges audit determinations and assessments, seeks refunds from state and local governments and handles administrative appeals, litigating unresolved disputes in state and local courts through post-trial appeals at all appellate levels.

Among other issues, Jennifer challenges taxing authorities' determinations of apportionment, sourcing, Public Law 86-272 protection, nexus-creating activities, the imposition of sales tax on evolving digital goods and services, and valuation and uniformity issues related to property tax assessments. Jennifer also helps clients seek refunds and reduce interest and penalties on past-due taxes through state and local amnesty, voluntary disclosure programs and administrative appeals.

On the planning side, she helps clients determine nexus and potential nexus for sales and use, income and gross receipts tax purposes and develop strategies to minimize exposure. She advises on the tax implications of pending and past transactions and helps clients mitigate tax burdens while maximizing available opportunities and credits.

Jennifer writes a quarterly article for Tax Notes State and contributes frequently to The Legal Intelligencer, Law360 and Bloomberg Tax. She is co-author of The Legal Intelligencer's Pennsylvania Tax Handbook and the Pennsylvania chapter of the American Bar Association's Property Tax Deskbook. Before joining the Firm, she chaired the state and local tax practice of a tax-focused Philadelphia law firm. That combination of litigation experience, planning insight and thought leadership helps clients resolve current disputes while managing future state and local tax exposure.

Representative Experience

  • Represented multistate corporations in challenging states' attempts 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

Education
  • Temple University, Beasley School of Law, J.D.
  • University of Delaware, B.A., cum laude
Bar Admissions/Licenses
  • Pennsylvania
  • New Jersey
Court Admissions
  • U.S. Supreme Court
Memberships
  • Philadelphia Bar Association, Tax Section, Chair 2025-2027; Vice Chair, 2024; Secretary-Treasurer, 2023; Tax Council, Elected Member, 2020-2022
  • Law360 Editorial Advisory Board, Tax Authority – State & Local, 2025, 2026
  • 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
Honors & Awards
  • The Best Lawyers in America guide, Philadelphia Litigation and Controversy – Tax Lawyer of the Year, 2027
  • The Best Lawyers in America guide, Tax Law, 2021-2027; Litigation and Controversy – Tax, 2026, 2027; Women in the Law, Business Edition, 2021
  • Chambers USA – America's Leading Business Lawyers guide, Tax, 2021-2026
  • Pennsylvania Super Lawyers magazine, 2025, 2026
  • Rising Star, International Tax Review World Tax, Tax Controversy, 2025
  • 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

Publications

Speaking Engagements

News