Crawford Moorefield

Senior Tax Counsel
[email protected]
(713)739-7007

About Crawford Moorefield

For over 35 years, Crawford has helped clients reach effective, practical solutions to complex business and tax issues. After working at some of the largest and most sophisticated international law firms in the country, he joined CJMH in 2024 as Senior Tax Counsel, bringing decades of experience as a trusted legal and business advisor specializing in transactional tax and business transactions.

Creative, resourceful, and thoughtful, Crawford enjoys “solving the puzzle” to determine the best and most tax-efficient strategy for each client and situation. By translating complex tax considerations into clear, plain language, Crawford helps his clients make critical decisions quickly and confidently.

There are very few tax or tax related business issues that cannot be solved – most in several different ways.  From equity flavored compensation by partnerships and corporations, foreign and tax exempt participation in U.S. assets and operations; insuring that tax credits flow to the parties able to use them with minimum leakage to tax indifferent parties, to capturing complex economic arrangements in partnerships and limited liability companies, all can be accomplished.  Achieving the desired results, however, requires knowledge, experience, and most of all creativity.

With broad industry experience, Crawford helps clients across a wide variety of industries, including oil and gas (from exploration and production (E&P), including oilfield services through midstream processing, transportation and storage to refining and manufacturing and transportation of refined products), timber, and other natural resources, filmed and recorded entertainment, healthcare, and real estate. His expertise includes state and local tax (SALT) issues, real estate investment trusts (REITS), master limited partnerships (MLPs), complex debt instruments, royalty trusts, and federal income tax matters related to inbound and outbound foreign transactions (e.g., FIRPTA).  Crawford also has substantial experience and expertise representing debtors and creditors in restructuring troubled companies both inside and out of bankruptcy court.  The dollar value of the many closed mergers and acquisitions transactions he advised on is well in excess of $30 billion.  He has advised issuers and underwriters in the issuance of well over $40 billion.

Crawford has also written and lectured widely for Tax Executives Institute, The State Bar of Texas Section of Taxation, Houston Bar Association, and other respected conferences.  He has also routinely participated in comments on Proposed Treasury Regulations through The State Bar of Texas and individually.  Crawford has served as chairman of the Energy and Natural Resources Taxation and Corporate Taxation Committee of The State Bar of Texas Section of Taxation, as well as an elected Council Member.  He is also a long-time Board Member of the Texas Federal Tax Institute.  Crawford is AV rated by Martindale Hubble and has been included in Texas Super Lawyers since 2007, Chambers USA from 2002 – 2010, and Best Lawyers in America for over 20 years.

Crawford has been quoted in major general interest news publications, including the Washington Post, The New York Times, and Business Week Texas Tax Lawyer winter 2018 and winter 2020.

Crawford earned a J.D. from Harvard Law School after graduating cum laude from Princeton University’s School of Public and International Affairs. Outside of work, he enjoys upland wingshooting, fishing, reading, cooking, and spending time with his wife and daughter.

Experience

  • 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).
  • Represented numerous publicly traded corporations in tax free spinoffs, as well as other complex restructurings
  • Obtained first IRS Private Letter Ruling sanctioning use of high/low voting stock to satisfy control requirement
  • Represented underwriter in first MLP to corporation conversion
  • 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.
  • 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.
  • Negotiating and structuring tax credit transfer transactions and securing IRS favorable private letter rulings on credit eligibility and validity of transfer structure.

Education

Harvard Law School, JD

Princeton University, AB, Cum Laude

 

Bar Admissions

State Bar of Texas

Languages

Fluent in Spanish

Conversational French

Practice Areas