Roy E. Crawford focuses his practice on corporate franchise and income taxation, personal income taxation, and sales and use taxation. He represents taxpayers in disputes and tax planning in many jurisdictions, with an emphasis in states that have adopted the Uniform Division of Income for Tax Purposes Act.
Previously, Roy was counsel in Crocker Equipment Leasing v. Oregon Dep’t of Rev., in which the Oregon Tax Court and Oregon Supreme Court upheld the right of a taxpayer to modify the statutory apportionment formula to include intangible personal property in the property factor. He was state tax and constitutional law counsel in Alabama v. Credit Card Companies, where the tax jurisdiction asserted over out-of-state banks, that had neither property nor employees in the state, was denied on the basis that the Alabama Legislature had not imposed a tax on out-of-state banks. Roy’s client, American General Corporation, was awarded the first litigation cost recovery in excess of one million dollars on the basis that the position of the Franchise Tax Board (FTB) was not substantially justified. The FTB did not appeal either the decision on the merits or the litigation cost recovery.
Roy has extensive experience working with the California FTB, the State Board of Equalization and the California Legislature on tax policy matters. He has lectured at many national tax conferences and has participated in tax policy conferences with the Multistate Tax Commission, state revenue departments, the American Bar Association and the California Bar Association, and is the author of three state tax portfolios published by Bloomberg BNA.
Received determination from FTB that liquidation of an insolvent subsidiary resulted in treatment of intercompany debt as a deemed contribution to capital, resulting in recognition of a multibillion-dollar worthless stock deduction
Resolved a dispute in which the FTB regarded the C election by a federal S corporation as an abusive tax avoidance transaction
Resolved a dispute in which the FTB regarded the combination of a homebuilding enterprise with a mortgage company as resulting in factor distortion
Represented, pro bono, a coalition of ranchers in relicensing grazing permits with the Bureau of Land Management (BLM)
Served as advisor to a coalition that resulted in legislation restoring tax benefits from qualified small business stock after the FTB regarded the Cutler decision as causing all benefits to be lost on a retroactive basis
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