 OverviewCrawford is a seasoned tax attorney with nearly 40 years of experience advising clients on complex transactional tax and business matters. His practice focuses on the tax aspects of mergers and acquisitions, joint ventures, partnerships, financings, restructurings, and other sophisticated business transactions. He also advises on tax-efficient ownership and compensation structures, tax credits, REITs, MLPs, complex debt instruments, and domestic and international tax matters. Throughout his career, Crawford has advised on more than $30 billion in completed M&A transactions and more than $40 billion in securities offerings. He represents clients across a range of industries, with significant experience in energy and natural resources, real estate, health care, and entertainment. Crawford also has extensive experience representing debtors and creditors in restructurings and other distressed situations, both in and outside of bankruptcy. Crawford brings a practical, solutions-oriented perspective to complex tax issues, helping clients evaluate potential structures and understand how tax considerations may affect the economics of a transaction. Drawing on decades of experience, he works closely with clients and their advisors to develop strategies tailored to their business objectives. Outside of work, he enjoys upland wingshooting, fishing, reading, cooking, and spending time with his wife and daughter. Memberships
- State Bar of Texas, Taxation Section, Energy and Natural Resources Taxation, and Corporate Taxation (Chairman; Council Member)
- Texas Federal Tax Institute (Board Member)
- American College of Tax Counsel (Fellow)
Languages
- Spanish (Fluent)
- French (Conversational)
OverviewCrawford is a seasoned tax attorney with nearly 40 years of experience advising clients on complex transactional tax and business matters. His practice focuses on the tax aspects of mergers and acquisitions, joint ventures, partnerships, financings, restructurings, and other sophisticated business transactions. He also advises on tax-efficient ownership and compensation structures, tax credits, REITs, MLPs, complex debt instruments, and domestic and international tax matters. Throughout his career, Crawford has advised on more than $30 billion in completed M&A transactions and more than $40 billion in securities offerings. He represents clients across a range of industries, with significant experience in energy and natural resources, real estate, health care, and entertainment. Crawford also has extensive experience representing debtors and creditors in restructurings and other distressed situations, both in and outside of bankruptcy. Crawford brings a practical, solutions-oriented perspective to complex tax issues, helping clients evaluate potential structures and understand how tax considerations may affect the economics of a transaction. Drawing on decades of experience, he works closely with clients and their advisors to develop strategies tailored to their business objectives. Outside of work, he enjoys upland wingshooting, fishing, reading, cooking, and spending time with his wife and daughter. ExperiencePublic Offerings + Publicly Traded PartnershipsRepresented issuers and underwriters in initial and subsequent public offerings of equity interests, as well as debt offerings [more]Represented issuers and underwriters in initial and subsequent public offerings of equity interests, as well as debt offerings in publicly traded partnerships (PTP’s; MLP’s). [less]Tax-Free Spinoffs + Corporate RestructuringsRepresented numerous publicly traded corporations in tax free spinoffs, as well as other complex restructurings. IRS Private Letter Ruling – High/Low Voting StockSecured the first IRS Private Letter Ruling approving a high/low voting stock structure to satisfy applicable control requirements. Master Limited Partnership ConversionRepresented an underwriter in connection with the first-ever conversion of a master limited partnership (MLP) to a corporation. Complex Joint Ventures + Partnership StructuresNegotiated hundreds of complex joint venture, partnership, and limited liability company agreements, including those [more]Negotiated hundreds of complex joint venture, partnership, and limited liability company agreements, including those with profits interests, multiple classes of equity, preferred returns, convertible equity and debt interests, targeted allocation provisions, New Centralized Partnership Audit Regime (“NCPAR”) compliant allocation, distribution, and transfer restriction provisions. [less]Restructurings, Bankruptcy + Bank FailuresRepresented debtors and creditors in dozens of complex restructurings, exchange offers, bankruptcy reorganizations [more]Represented debtors and creditors in dozens of complex restructurings, exchange offers, bankruptcy reorganizations and liquidations including creditors trusts, oil and gas companies. Also represented creditors in the two largest bank failures in Texas history, with all creditors being paid in full in both cases. [less]Tax Credit Transfer TransactionsNegotiating and structuring tax credit transfer transactions and securing IRS favorable private letter rulings on credit eligibility [more]Negotiating and structuring tax credit transfer transactions and securing IRS favorable private letter rulings on credit eligibility and validity of transfer structure. [less]
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