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Craig regularly litigates state and local tax matters as well as 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, he has resolved hundreds of non-public record cases around the country.He has secured successful outcomes for clients in state general jurisdiction courts and tax courts as well as appellate courts for a multitude of clients across various industries. He has also advised clients on the potential state and local tax consequences of complex restructurings involving corporation income (franchise) taxes, sales and use taxes, and miscellaneous taxes.Craig has published numerous articles on state and local taxation, which have appeared in leading industry publications such as the Journal of State Taxation, State Tax Notes, Tax Management’s Multistate Tax Report, COST’s State Tax Report, TEI’s Tax Executive, Research Institute of America’s State and Local Taxes Weekly, the Journal of Multistate Taxation and Incentives, Law360, Cyberspace Lawyer, the Interstate Tax Report, and The American Bar Association’s The State &amp; Local Tax Lawyer.Craig also frequently delivers lectures on state and local tax issues and has spoken before many organizations, including the National Multistate Tax Symposium, New York University’s Institute on State and Local Taxation, Vanderbilt University Law School’s Paul J. Hartman State and Local Tax Forum, Georgetown University Law Center’s Advanced State and Local Tax Institute, the Tax Executives Institute, the Council On State Taxation, the Energy Tax Association, STARTUP, the Chicago Tax Club, the Tulane Tax Institute, Practicing Law Institute, and the Tax Section of the American Bar Association.

core/freeform

Connecticut

District of Columbia

Massachusetts

New York

Aerospace, Defense & Government Services

ADG State + Local Tax

46th TEI Region 10 Annual Conference

What’s Shaking: Blank Rome’s State + Local Tax Roundup

Plain and Ordinary Meaning of Exemption Statute Results in Indiana Use Tax Victory

The BR State + Local Tax Spotlight: April 2026

COST 2026 Spring Conference / Audit Session

Back to the Basics: Statutory Interpretation

Perseverance Leads to Victory in New York Sales Tax Dispute

The BR State + Local Tax Spotlight: February 2026

Tax Audit Lifecycle: Controversy Coping Mechanisms for Adapting and Thriving

Planning for Aggressive Audits in the Wake of Budget Shortfalls

State and Local Tax Policy to Watch in 2026

Taxpayer Fails to Overcome California Assessment Based on Federal Change

The BR State + Local Tax Spotlight: December 2025

Blank Rome Tax Update 2025

44th Institute on State and Local Taxation

2025 California All-Tax Conference

32nd Annual Paul J. Hartman State and Local Tax Forum

What’s Shaking: Blank Rome’s State + Local Tax Roundup October 2025

Pennsylvania Supreme Court Confirms That Pittsburgh’s Tax on Only Nonresident Athletes and Entertainers Violates Commonwealth’s Uniformity Clause

The BR State + Local Tax Spotlight: October 2025

Internet Tax Freedom Act Preempts New York’s Imposition of Tax

The BR State + Local Tax Spotlight: August 2025

Blank Rome Attorneys Recognized in 2026 Best Lawyers in America®

The BR State + Local Tax Spotlight: June 2025

New Jersey Required to Turn Square Corners and Pay Untimely Filed Refund Claim

Blank Rome Attorneys and Practices Highly Ranked in The Legal 500 United States 2025

Chambers USA 2025 Recognizes Blank Rome Attorneys and Practices

2025 TEI Region 10 Conference

What’s Shaking: Blank Rome State + Local Tax Roundup

Blank Rome Attorneys Recognized in 2025 Lawdragon 500 Leading Global Tax Lawyers

State of the States 2025

State of the States (2025)

COST 2025 Spring Conference / Audit Session

Gains on Sales of Franchises Held Nonbusiness Income in Arkansas

What’s Shaking: Blank Rome State + Local Tax Roundup (April 2025)

The BR State + Local Tax Spotlight: April 2025

What’s Shaking: Blank Rome State + Local Tax Roundup: March 2025

The BR State + Local Tax Spotlight: March 2025

LLC’s Splitting into Six Companies Not Subject to Pennsylvania Realty Transfer Tax

The BR State + Local Tax Spotlight: February 2025

M&A Twists and Turns: Transaction Tips for Multistate Direct and Indirect Taxes

Virginia Court Rules That Corporation Is Not Unitary with 17% Owned Limited Liability Company

The BR State + Local Tax Spotlight: December 2024

The BR State + Local Tax Spotlight: November 2024

Blank Rome Tax Update 2024

Kentucky Court Issues Permanent Injunction of Law Discriminating Against Interstate Commerce

The BR State + Local Tax Spotlight: October 2024

COST’s 55th Annual Meeting

The BR State + Local Tax Spotlight: September 2024

Despite Being an Officer and Previously Writing Checks for a Business, New York Concludes Individual Is Not a Responsible Person

The BR State + Local Tax Spotlight: August 2024

The BR State + Local Tax Spotlight: July 2024

Southwest/West Regional State Tax Seminar

Missouri Court Rules Nonresidents Not Subject to Local Tax When Working Outside the Locality

The BR State + Local Tax Spotlight: June 2024

Blank Rome Attorneys and Practices Highly Ranked in The Legal 500 United States 2024

Chambers USA 2024 Recognizes Blank Rome Attorneys and Practices

2024 TEI Region 10 Conference

State of the States

The BR State + Local Tax Spotlight: May 2024

Economic Substance

COST 2024 Spring Conference & Audit Session

South Carolina Legislature Severely Limits Department’s Ability to Force Companies to File Combined Returns

The BR State + Local Tax Spotlight: April 2024

The BR State + Local Tax Spotlight: March 2024

Pennsylvania Commonwealth Court Affirms That Pittsburgh’s Tax on Only Nonresident Athletes Violates State’s Uniformity Clause

The BR State + Local Tax Spotlight: February 2024

Alternative Apportionment and Forced Combination—Dishing on the Latest

The BR State + Local Tax Spotlight: January 2024

New Jersey Agency Required to Honor its Deal and Allow $26 Million in Tax Credits

The BR State + Local Tax Spotlight: December 2023

The BR State + Local Tax Spotlight: November 2023

2023 Annual Meeting of the Tax Bar and Tax Policy Conference

Receipts from Products Delivered to Ohio Distribution Center for Subsequent Shipment Outside the State Are Not Sourced to Ohio

The BR State + Local Tax Spotlight: October 2023

COST’s 54th Annual Meeting

The BR State + Local Tax Spotlight: September 2023

New York State Judge Rules for Securities Broker-Dealer on Corporate Tax Sourcing, Investment Income, and Investment Tax Credits

State + Local Tax

Appellate Litigation

Tax Controversy

<ul>
<li>Represented a generator and wholesaler of electricity before the New York State Tax Appeals Tribunal, which agreed with us and held in a precedential decision that the company is subject to the $350,000 cap applicable to qualified New York manufacturers in computing the capital base of its corporation franchise tax liability.</li>
<li>Represented an American public research, development, and manufacturing company before the Colorado Supreme Court, which 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.</li>
<li>Represented an American department store retail chain before the Virginia Supreme Court, which held in a 4-3 decision 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.</li>
<li>Represented a former Fortune 500 chief financial officer (“CFO”) who was based in New York City while CFO, but then retired and moved to Paris to be with his wife, a French domiciliary with whom he rekindled a relationship after more than 40 years apart. A New York State administrative law judge held that the CFO was no longer domiciled in New York and therefore could no longer be taxed as a New York State and City resident.</li>
<li>Represented an American electric power holding company before the New Jersey Tax Court, which 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.</li>
<li>Represented an American lifestyle clothing and accessories retailer before the Indiana Tax Court, which granted partial summary judgment against the Department of Revenue in a forced combination case.</li>
</ul>

Craig B. Fields

Craig B. Fields

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