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Craig B. Fields

Partner
New York, (212) 468-8193

Craig B. Fields is co-chair of the firm’s Tax Department and is also chair of the firm’s State + Local Tax Group. His practice focuses on litigation and planning relating to state and local tax matters. He has been involved in controversies regarding state and local tax issues before the administrative and judicial systems of jurisdictions throughout the United States as well as having resolved hundreds of non-public record cases around the country. Mr. Fields has also provided advice regarding the potential tax consequences of complex restructurings involving the corporation income (franchise) taxes, the sales and use taxes, and miscellaneous taxes of many jurisdictions.

Mr. Fields is recommended as a leading state tax lawyer by Chambers USA 2012 and 2013. He is recognized by Legal 500 US 2011 – 2013, and has been consistently ranked in Super Lawyers since 2006. He has been named to State Tax Notes’ “Top 10 Tax Lawyers” list for 2011.

Mr. Fields has written extensively in the area of state and local taxation. His articles have appeared in numerous publications, including Tax Management’s Multistate Tax Report, State Tax Notes, Research Institute of America’s State and Local Taxes Weekly, the COST State Tax Report, the Journal of State Taxation, the Journal of Multistate Taxation and Incentives, the Journal of New York Taxation, Interstate Tax Report, and the American Bar Association’s The State & Local Tax Lawyer. He is a contributing author to a chapter in “Doing business in the United States: New York,” a handbook in the Practical Law Company’s “PLC Cross-border” series.

Mr. Fields is also a frequent lecturer concerning state and local taxes and has spoken before such organizations as New York University’s Institute on State and Local Taxation, Georgetown University Law Center’s Advanced State and Local Tax Institute, Vanderbilt University Law School’s Paul J. Hartman State and Local Tax Forum, the Council On State Taxation, the Energy Tax Association, STARTUP, the Tax Executives Institute, the Tulane Tax Institute, the Practicing Law Institute, and the Tax Section of the American Bar Association. Mr. Fields is a member of the Georgetown Law Center Advisory Board.

AE Outfitters Retail Co.
The Indiana Tax Court granted partial summary judgment against the Department of Revenue in a forced combination case.
GMRI, Inc. (Red Lobster, Olive Garden)
The California State Board of Equalization ruled that the State could not impose sales tax on certain restaurant gratuity checks of parties of eight or more customers (called “large parties”).
Sherwin-Williams Co.
The Supreme Judicial Court of Massachusetts held that companies may legally reorganize themselves and, as long as the reorganization has economic substance, it must be respected for tax purposes even if the new structure also provides tax benefits.
ABB C-E Nuclear Power, Inc.
The Missouri Supreme Court ruled that the gain recognized by a corporation from the sale of a subsidiary in an IRC Section 338(h)(10) transaction constituted non-business income for Missouri tax purposes.
Osram Sylvania, Inc.
The Pennsylvania Supreme Court affirmed the decision of the Commonwealth Court and held that the gain from an IRC Section 338(h)(10) election constituted non-business income for Pennsylvania corporate net income tax purposes.
In re Verizon Yellow Pages Company f/k/a Bell Atlantic Yellow Pages Company
The New York Division of Tax Appeals ruled that a company which purchased telephone directories and distributed them to its customers and potential customers was entitled to the sales and use tax exemption provided for promotional materials.
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