Craig is co-chair of MoFo’s Tax Department and chair of the firm’s State + Local Tax Group. He regularly litigates state and local tax matters and counsels clients on state and local tax planning.
In addition to representing clients in state and local tax controversies before administrative and judicial systems in jurisdictions throughout the United States, Craig has resolved hundreds of non-public record cases around the country.
One of Craig’s clients told Chambers USA 2018: “He is technically and procedurally great.”
Craig has secured successful outcomes for clients in state general jurisdiction courts and tax courts as well as appellate courts for a multitude of clients, including:
He has also advised clients on the potential tax consequences, in many jurisdictions, of complex restructurings involving:
Craig received the NYU School of Professional Studies Paul H. Frankel Award for Outstanding Achievement in State and Local Taxation in 2017.
In 2019 he was selected as a Fellow of the American Bar Foundation.
Craig’s articles on U.S. state-and-local taxation have appeared in publications, including:
Craig also frequently delivers lectures on state-and-local tax issues and has spoken before organizations including:
Craig is a member of:
Agilent Technologies, Inc.The Colorado Supreme Court held that the Department of Revenue could not forcibly include in a combined return a corporation’s subsidiary, a holding company that derived its income solely from investments in foreign entities, inasmuch as the Department was bound by its own regulation, which provided that a corporation without any property or payroll of its own cannot be included in a Colorado combined return.
Kohl’s Department Stores, Inc.The Virginia Supreme Court, in a 4-3 decision, held that the subject-to-tax safe harbor to the royalty addback was ambiguous and applies only to the extent that the royalties are actually taxed by another state. In addition, the court agreed with the company’s alternative argument that a portion of the royalties qualify for the safe harbor when: (1) the royalties are taxed by states that require the royalty payor to add back the royalty payments; or (2) the royalties are taxed by states that require combined or consolidated reporting.
Former CFO of Fortune 500 CompanyA New York State Administrative Law Judge held that the former Chief Financial Officer of a Fortune 500 Company, who was based in New York City while CFO but retired and then moved to Paris to be with his wife, a French domiciliary with whom he rekindled a relationship after more than 40 years apart, clearly established that he was no longer domiciled in New York, and therefore could no longer be taxed as a New York State and City resident.
Duke Energy CorporationThe New Jersey Tax Court held that electric utilities taxes paid to North Carolina and South Carolina are not taxes “on or measured by profits or income, or business presence or business activity” and, therefore, are not required to be added back to the taxpayer’s federal taxable income for Corporation Business Tax purposes.
AE Outfitters Retail Co.The Indiana Tax Court granted partial summary judgment against the Department of Revenue in a forced combination case.
Agilent Technologies, Inc.The Colorado Court of Appeals held that the Department of Revenue could not forcibly include in a combined return a corporation’s subsidiary, a holding company that derived its income solely from investments in foreign entities, inasmuch as the Department was bound by its own regulation, which provided that a corporation without any property or payroll of its own cannot be included in a Colorado combined return.
Chambers USA has ranked Mr. Fields as a leading state tax lawyer since 2012. In addition, Legal 500 US has recommended him since 2011 and he has been ranked consistently in Super Lawyers since 2006. He was also named to State Tax Notes’ “Top 10 Tax Lawyers” list in 2011.
What Clients Are Saying
"He's very valuable on the SALT side," says a client, citing his "knowledge and ability to deal with issues. If I have a question, he gets back to me quickly."– Chambers USA 2019
“He is technically and procedurally great; he has a good demeanor in controversy settings and is a very effective listener.”– Chambers USA 2018
Clients attest: “He is excellent with legal analysis, strategy development and follow-through.”– Chambers USA 2017
Clients say: “He knows to be aggressive or assertive as we want, and has a great level of experience. He gets a successful outcome very consistently. His interpersonal skills are excellent, engaging but not overwhelming; he comes at it with a nice balance.” – Chambers USA 2016
Interviewees say: “He is adept at negotiating settlements and formulating strategies to resolve issues favourably and expediently.” – Chambers USA 2015
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