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PRESENTED BY
The University of Texas School of Law
The Office of Chief Counsel, Internal Revenue Service
 
RECEPTION SPONSORS*
Baker Botts L.L.P.
Bracewell & Giuliani LLP
Ceteris
Deloitte Tax LLP
Ernst & Young LLP
Fulbright & Jaworski L.L.P.
KPMG LLP
Miller & Chevalier Chartered
PricewaterhouseCoopers LLP
Thompson & Knight LLP
Vinson & Elkins LLP

*Note: The Internal Revenue Service and the U.S. Department of the Treasury are not sponsoring the reception and their participation in the reception is not intended as an endorsement of the reception or the sponsors.
Conference art

11th Biennial

Oil and Gas Tax Conference

Houston Oct 27-28, 2011 Omni Houston Galleria
Conference Concluded
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Overview

Join a nationally recognized faculty and an audience of more than 400 members of the oil, gas and energy tax community—including senior government officials, IRS staff, corporate energy and tax counsel, and members of the energy tax bar—at the 2011 Parker C. Fielder Oil and Gas Tax Conference.

The conference takes place October 27-28, 2011, at the Omni Houston Galleria. This event is a unique collaboration between the University of Texas School of Law and the Chief Counsel’s Office of the IRS: it provides an exchange of views and perspectives between private sector and the Service.

The 2011 program opens with a sophisticated overview of shale gas plays and production, including technology, economics, business and regulatory issues, and continues with presentations, panels and discussions of current energy taxation issues including:

•    Capital Cost Recovery panel moderated by Thomas Evans
•    Current Issues and Trends in Acquisitions and Dispositions of Oil and Gas Properties
•    Current Partnership Tax Issues in the Energy Industry
•    Building Blocks of Oil and Gas Taxation: The Economics and Taxation of Production Payments; and
      Like-Kind Exchanges in the Energy Sector
•    International Energy Tax: Foreign Tax Credit Issues; and Transfer Pricing
•    Latest Techniques and Trends to Resolve an LB&I Audit

The program also features:

•    IRS Chief Counsel William J. Wilkins delivering the keynote luncheon presentation on
      Current Developments in Tax Administration
•    An hour on Ethics and Professional Responsibility Issues with Office of Professional Responsibility
      Director Karen L. Hawkins, and Emily A. Parker
•    A special awards presentation honoring R. Richard Coston of Fulbright & Jaworski L.L.P.,
      Thomas Crichton IV of Vinson & Elkins LLP, and Keith M. Jones, Industry Director of Natural Resources &
      Construction-LMSB for the IRS, for their outstanding service and achievement in oil and gas taxation

If your work involves energy taxation law or finance, you won’t want to miss this exceptional educational and networking event.

  • Buy

Event Schedule

Program is subject to change.
All times are Central Time Zone.

  • Day 1 October 27, 2011
  • Day 2 October 28, 2011
  • Time
    Credit
    Subject
    Speaker
  • Thursday Morning, Oct. 27, 2011
  • 8:00 am
    Registration Opens
    Includes continental breakfast.

  • 8:20 am
    Welcoming Remarks

  • 8:30 am
    0.75 hr
    Shale Gas: Technology, Economics and Business
    The rapid evolution of shale gas production has taken much of the industry by surprise. What is the current state of progress and development, and what are the impacts of low gas prices and resistance to hydraulic fracturing likely to be? Will new sources of demand such as LNG exports have an impact, and how will development relate to unconventional oil development?

    Richard G. Smead, Navigant Consulting, Inc. - Houston, TX

  • 9:15 am
    1.25 hrs
    Capital Cost Recovery
    A discussion of key capital cost recovery issues, including repair regulations, safe harbor for deducting success-based fees in M&A acquisitions, first year's experience with Schedule UTP, accounting method changes for CFCs, casualty losses, delay rentals, and bonus depreciation.

    Moderator:
    Thomas L. Evans, Kirkland & Ellis LLP - Chicago, IL
    Panelists:
    Stephen E. Comstock, American Petroleum Institute - Washington, DC
    Panelists:
    John F. Eiman, Internal Revenue Service, LB&I - Houston, TX
    Panelists:
    Ellen MacNeil, Deloitte & Touche LLP - Washington, DC
    Panelists:
    Kathleen Reed, Internal Revenue Service - Washington, DC

  • 10:30 am
    Break

  • 10:45 am
    1.50 hrs
    Current Issues and Trends in Acquisitions and Dispositions of Oil and Gas Properties
    This panel explores current issues and trends in the acquisition and disposition of oil and gas properties both onshore in the newer shale gas and oil resource plays and offshore in the shallow waters of the Gulf of Mexico. Areas of focus include acquisition structures such as the cash and carry partnership and the leveraged partnership for onshore acquisitions, and the special needs for structuring buyer's assumption of seller's federal plugging and abandonment obligations in the Gulf.

    Moderator:
    John T. Bradford, Liskow & Lewis - Houston, TX
    Panelists:
    Timothy J. Devetski, Vinson & Elkins LLP - Houston, TX
    Panelists:
    Amy Sutton, Deloitte Tax LLP - Houston, TX
    Panelists:
    James Toups, Apache Corporation - Houston, TX
    Panelists:
    Clifford Warren, IRS - Washington, DC

  • 12:15 pm
    Adjourn to Luncheon
    Included in conference registration fee.

  • Thursday Afternoon, Oct. 27, 2011
  • LUNCHEON AND AWARD PRESENTATION

  • 12:45 pm
    Parker C. Fielder Award Presentation
    Presentation by Robert Peroni and John Dzienkowski

    Award Recipients:
    R. Richard Coston, Fulbright & Jaworski L.L.P, Houston, TX
    Thomas Crichton IV, Vinson & Elkins LLP, Dallas, TX
    Keith M. Jones, Internal Revenue Service, Houston, TX

  • Luncheon Presentation Introduction
    C. Elizabeth Wagner, Internal Revenue Service, Washington, D.C.

  • Keynote Luncheon Presentation

  • 1:00 pm
    0.50 hr
    Current Developments in Tax Administration

    William J. Wilkins, Internal Revenue Service - Washington, DC

  • 1:30 pm
    Break

  • 1:45 pm
    1.25 hrs
    Current Partnership Tax Issues in the Energy Industry: Leveraged Partnership Transactions after Canal, Series LLCs in Energy Transactions and Other Hot Topics
    This panel discusses the future of leveraged partnership transactions following Canal v. Commissioner; an overview of the proposed regulations on the classification of Series LLCs and their potential application in energy transactions; the "carried interest" legislative proposals and how they would impact oil and gas partnerships; and a look at new issues affecting MLPs.

    Moderator:
    Paul Kugler, KPMG LLP - Washington, DC
    Panelists:
    Christopher T. Kelley, Internal Revenue Service - Washington, DC
    Panelists:
    Karen Lohnes, PricewaterhouseCoopers L.L.P. - Washington, DC
    Panelists:
    Gregory V. Nelson, Baker Botts L.L.P. - Houston, TX

  • 3:00 pm
    Break

  • Track A: Building Blocks of Oil and Gas Taxation and Their Applications
  • 3:15 pm
    1.25 hrs
    Production Payments: Concepts, Economics and Taxation
    This panel explores the unique nature of oil and gas production payments from both an economic and tax perspective: how production payments differ from other types of mineral sharing arrangements, the different types of production payments, how the application of general tax principles to production payments led to the enactment of special rules in Section 636 treating certain production payments as loans, the interplay between Section 636 and the OID rules for debt instruments, and current uses of production payments in oil and gas transactions.

    Moderator:
    David B. Cubeta, Miller & Chevalier Chartered - Washington, DC
    Panelists:
    Noah Baer, Ernst & Young National Tax - Washington, DC
    Panelists:
    George Edward Gasper, IRS - Farmers Branch, TX

  • 4:30 pm
    1.00 hr
    Like-Kind Exchanges in the Energy Sector
    Once again Section 1031 exchanges involving oil and gas are heating up. This panel focuses on special issues affecting oil and gas Section 1031 exchanges, including  carved out interests, sale vs. lease, recapture, tax partnerships, the mandatory application of Section 1031, reverse exchanges and related party transactions.

    J. Peter Baumgarten, Internal Revenue Service - Washington, DC
    Todd Denison Keator, Thompson & Knight LLP - Dallas, TX

  • Track B: International Tax Issues
  • 3:15 pm
    1.25 hrs
    Foreign Tax Credit Issues
    A discussion of current foreign tax credit issues including any recent developments with respect to Sections 909 and 901(m).

    Moderator:
    Rebecca I. Rosenberg, PricewaterhouseCoopers L.L.P. - Washington, DC
    Panelists:
    Heather B. Crowder, ConocoPhillips - Houston, TX
    Panelists:
    Ronald A. Dabrowski, Internal Revenue Service - Washington, DC
    Panelists:
    Anne Devereaux, Internal Revenue Service - Washington, DC
    Panelists:
    Kevin L. Kenworthy, Miller & Chevalier Chartered - Washington, DC

  • 4:30 pm
    1.00 hr
    Transfer Pricing
    The panelists discuss transfer pricing issues particularly relevant to the oil, gas and energy industry, including IRS initiatives, legislative proposals, arm's length charges for related party services, and development and use of intangible property.

    Moderator:
    Steven C. Wrappe, Ernst & Young LLP - Washington, DC
    Panelists:
    Samuel M. Maruca, Internal Revenue Service - Washington, DC
    Panelists:
    Steven A. Musher, Internal Revenue Service - Washington, DC
    Panelists:
    Paul M. Schmidt, Baker & Hostetler LLP - Washington, DC

  • 5:30 pm
    Adjourn to Reception

    RECEPTION SPONSORS*
    Baker Botts L.L.P.
    Bracewell & Giuliani LLP
    Ceteris
    Deloitte Tax LLP
    Ernst & Young LLP
    Fulbright & Jaworski L.L.P.
    KPMG LLP
    Miller & Chevalier Chartered
    PricewaterhouseCoopers LLP
    Thompson & Knight LLP
    Vinson & Elkins LLP

    *Note: The Internal Revenue Service and the U.S. Department of the Treasury are not sponsoring the reception and their participation in the reception is not intended as an endorsement of the reception or the sponsors.

  • Time
    Credit
    Subject
    Speaker
  • Friday Morning, Oct. 28, 2011
  • 8:30 am
    1.25 hrs
    Restructuring and M&A in the Energy Sector: Tools, Techniques, and Select Domestic and International Issues
    This panel considers the various ways an LLC can be used in structuring mergers and acquisitions in order to accomplish either commercial goals or tax goals, and examines recent transactions of interest, including the separation of exploration and production activities from downstream activities as illustrated by the spinoffs recently announced by El Paso Corporation, Marathon Oil Corporation and Williams Companies. The panel concludes with a summary of select international tax issues facing the oil and gas industry, and a proposed structure using a Series LLC to avoid an outbound transfer of foreign producing prospects while obtaining ordinary loss treatment for prospects with dry holes.

    Moderator:
    Edward C. Osterberg Jr., Vinson & Elkins LLP - Houston, TX
    Panelists:
    David B. Bailey, Internal Revenue Service - Washington, DC
    Panelists:
    Stephen A. Kuntz, Fulbright & Jaworski LLP - Houston, TX
    Panelists:
    James Dennis Reardon, Bracewell & Giuliani LLP - Houston, TX

  • 9:45 am
    1.00 hr ethics
    Ethics and Professional Responsibility Issues
    The Director of OPR and the moderator join in a candid discussion of the ethical and professional responsibilities of those who practice before the IRS, including relevant revisions to Circular 230 that went into effect August 2, 2011.

    Moderator:
    Emily A. Parker, Thompson & Knight LLP - Dallas, TX
    Commentator:
    Karen L. Hawkins, Internal Revenue Service, Office of Professional Responsibility - Washington, DC

  • 10:45 am
    Break

  • 11:00 am
    1.50 hrs
    Latest Techniques and Trends to Resolve an LB&I Audit
    The panel explores tips and strategies for the most effective techniques for working through an LB&I audit. Topics include successful audit communication techniques, alternative dispute resolution techniques (including the most efficient utilization of fast track, early referral and post-Appeals mediation), and participation in CAPS.

    Moderator:
    Richard A. Husseini, Baker Botts L.L.P. - Houston, TX
    Panelists:
    Joseph F. Andolino, Halliburton - Houston, TX
    Panelists:
    Keith M. Jones, Internal Revenue Service, LB&I Counsel - Houston, TX
    Panelists:
    Peter Andrew Lowy, Shell Oil Company - Houston, TX
    Panelists:
    Michael J. Walker, Internal Revenue Service - Los Angeles, CA

  • 12:30 pm
    Adjourn

  • Day 1 October 27, 2011
  • Day 2 October 28, 2011
Download Schedule

Conference Faculty

Joseph F. Andolino

Halliburton
Houston, TX

Noah Baer

Ernst & Young National Tax
Washington, DC

David B. Bailey

Internal Revenue Service
Washington, DC

J. Peter Baumgarten

Internal Revenue Service
Washington, DC

John T. Bradford

Liskow & Lewis
Houston, TX

Stephen E. Comstock

American Petroleum Institute
Washington, DC

Heather B. Crowder

ConocoPhillips
Houston, TX

David B. Cubeta

Miller & Chevalier Chartered
Washington, DC

Ronald A. Dabrowski

Internal Revenue Service
Washington, DC

Anne Devereaux

Internal Revenue Service
Washington, DC

Timothy J. Devetski

Vinson & Elkins LLP
Houston, TX

John F. Eiman

Internal Revenue Service, LB&I
Houston, TX

Thomas L. Evans

Kirkland & Ellis LLP
Chicago, IL

George Edward Gasper

IRS
Farmers Branch, TX

Karen L. Hawkins

Internal Revenue Service, Office of Professional Responsibility
Washington, DC

Richard A. Husseini

Baker Botts L.L.P.
Houston, TX

Keith M. Jones

Internal Revenue Service, LB&I Counsel
Houston, TX

Todd Denison Keator

Thompson & Knight LLP
Dallas, TX

Christopher T. Kelley

Internal Revenue Service
Washington, DC

Kevin L. Kenworthy

Miller & Chevalier Chartered
Washington, DC

Paul Kugler

KPMG LLP
Washington, DC

Stephen A. Kuntz

Fulbright & Jaworski LLP
Houston, TX

Karen Lohnes

PricewaterhouseCoopers L.L.P.
Washington, DC

Peter Andrew Lowy

Shell Oil Company
Houston, TX

Ellen MacNeil

Deloitte & Touche LLP
Washington, DC

Samuel M. Maruca

Internal Revenue Service
Washington, DC

Steven A. Musher

Internal Revenue Service
Washington, DC

Gregory V. Nelson

Baker Botts L.L.P.
Houston, TX

Edward C. Osterberg Jr.

Vinson & Elkins LLP
Houston, TX

Emily A. Parker

Thompson & Knight LLP
Dallas, TX

James Dennis Reardon

Bracewell & Giuliani LLP
Houston, TX

Kathleen Reed

Internal Revenue Service
Washington, DC

Rebecca I. Rosenberg

PricewaterhouseCoopers L.L.P.
Washington, DC

Paul M. Schmidt

Baker & Hostetler LLP
Washington, DC

Richard G. Smead

Navigant Consulting, Inc.
Houston, TX

Amy Sutton

Deloitte Tax LLP
Houston, TX

James Toups

Apache Corporation
Houston, TX

Michael J. Walker

Internal Revenue Service
Los Angeles, CA

Clifford Warren

IRS
Washington, DC

William J. Wilkins

Internal Revenue Service
Washington, DC

Steven C. Wrappe

Ernst & Young LLP
Washington, DC

Planning Committee

John S. Dzienkowski—Co-Chair

The University of Texas School of Law
Austin, TX

Robert J. Peroni—Co-Chair

The University of Texas School of Law
Austin, TX

John T. Bradford

Liskow & Lewis
Houston, TX

David W. Carter

Internal Revenue Service
Atlanta, GA

Stephen E. Comstock

American Petroleum Institute
Washington, DC

R. Richard Coston

Fulbright & Jaworski L.L.P.
Houston, TX

Heather B. Crowder

ConocoPhillips
Houston, TX

David B. Cubeta

Miller & Chevalier Chartered
Washington, DC

Robert Deitz

Sunoco, Inc.
Philadelphia, PA

Anne Devereaux

Internal Revenue Service
Washington, DC

Kimberly Edwards

Internal Revenue Service
Houston, TX

John F. Eiman

Internal Revenue Service, LB&I
Houston, TX

Michael J. Esposito

The University of Texas School of Law
Austin, TX

Charles S. Felice Jr.

Exxon Mobil Corporation
Houston, TX

Alan L. Fischl

PricewaterhouseCoopers L.L.P.
Washington, DC

Richard D. Fultz

Internal Revenue Service
Washington, DC

Janet Gordon

Internal Revenue Service
Houston, TX

Richard A. Husseini

Baker Botts L.L.P.
Houston, TX

Keith M. Jones

Internal Revenue Service, LB&I Counsel
Houston, TX

Kevin L. Kenworthy

Miller & Chevalier Chartered
Washington, DC

Ellen Kolpin

Internal Revenue Service
Houston, TX

Terry A. Loendorf

Internal Revenue Service
Farmers Branch, TX

Phillip L. Mann

Miller & Chevalier Chartered
Washington, DC

Bobby Marandi

PricewaterhouseCoopers L.L.P.
Houston, TX

Anthony H. Martinez

Internal Revenue Service
Albuquerque, NM

Martha McRee

Internal Revenue Service
Washington, DC

Jaime Park

Internal Revenue Service
Washington, DC

Charles Pierce

American Petroleum Institute
Washington, DC

Douglas Poms

KPMG LLP
Washington, DC

Byron Ratliff

PricewaterhouseCoopers L.L.P.
Houston, TX

Tim C. Raymond

Exxon Mobil
Houston, TX

Robert A. Swiech

KPMG Washington National Tax
Houston, TX

C. Elizabeth Wagner

Internal Revenue Service
Washington, DC

Ken Wood

Ernst & Young LLP
Washington, DC

Steven C. Wrappe

Ernst & Young LLP
Washington, DC

Jeffery M. Wright

Deloitte Tax LLP
Houston, TX

Credit Info

  • Houston
MCLE Credit
Toggle view Texas – 11.25 hrs  |  1.00 hrs Ethics
Legal Specialization(s): Oil, Gas and Mineral Law, Tax Law
You may claim your credit online in Your Briefcase, and UT Law CLE will report credit on your behalf to the State Bar of Texas. A Certificate of Attendance will be provided in Your Briefcase for your records. The system reports Texas CLE credit every Tuesday. If you are claiming credit in the last week of your birth month, self-report your CLE credit directly to the State Bar of Texas at texasbar.com, using the course number  provided on your certificate of attendance.
Toggle view California – 11.25 hrs  |  1.00 hrs Ethics
You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. UT Law CLE is required to provide the State Bar with electronic attendance records for any MCLE participatory activity within 60 days of completion of the activity. The California licensee is responsible for reporting their compliance/credit hours earned to the State Bar at the end of their reporting period directly to the State Bar of California at calbar.ca.gov.  UT Law CLE will maintain Attendance Records for four years.  
Other Credit
Toggle view TX Accounting CPE – 13.50 hrs
The University of Texas School of Law (Provider #250) live conferences are presumptively approved by The Texas State Board of Public Accountancy for Texas Accounting CPE credit based on a 50-minute credit hour. Approved for general CPE credit only.

At the conference, you are welcome to sign in on the Accounting CPE Record of Attendance form at the registration desk, but we are now reporting all credit online. You will receive a Texas Accounting Certificate of Completion in Your Briefcase. Self-report your CPE credit directly to TSBPA. UT Law CLE will maintain Attendance Records for four years.  

Contact us at accreditation@utcle.org if you have additional questions.

Key Dates

Houston – Oct 27-28, 2011 – Omni Houston Galleria
Conference Concluded
Buy
  • Houston
Standard Registration
Last day for $545.00 Regular pricing: Oct 19, 2011

$595.00 for registrations received after this time

Last day for cancellation (full refund): Oct 21, 2010

$50 processing fee applied after this date

Last day for cancellation: Oct 24, 2011

Venue

speaker

Omni Houston Galleria

4 Riverway
Houston, TX
713-871-8181 (reservations)
Map

Accommodations

$149.00 good through Sep 26, 2011

Parking Information

$12 Valet per day, $24 Overnight Valet, Complimentary self parking

Our Sponsors

Thank you to our sponsors! Click each logo below to learn more.

  • Baker Botts L. L. P.

    Baker Botts L. L. P.
    Baker Botts is an international law firm recognized for their creative approach to the legal and business issues facing their clients. With approximately 800 lawyers and worldwide network of offices, Baker Botts works with their clients on a wide range of matters. Our approach to the law practice is collaborative, with lawyers functioning as integrated teams to bring the most appropriate response to client needs. www.bakerbotts.com www.bakerbotts.com/
  • Bracewell & Giuliani, Llp

    Bracewell & Giuliani, Llp
    Bracewell & Giuliani LLP is a prominent international law firm with more than 450 lawyers in Texas, New York, Washington, DC, Connecticut, Dubai, Kazakhstan and London. They serve major financial institutions, leading private investment funds, Fortune 500 companies, governmental entities and individuals concentrated in the energy and financial services sectors worldwide. Bracewell provides guidance on business law, finance, litigation, government relations and regulatory policy. www.bracewellgiuliani.com bracewell.com/
  • Ceteris

    Ceteris
    www.ceterisgroup.com/index.php
  • Deloitte Tax Llp

    Deloitte Tax Llp
  • Ernst & Young

    Ernst & Young
  • Fulbright & Jaworski L.L.P. logo
    Fulbright & Jaworski L.L.P.
    The Fulbright Arbitration and ADR group is widely recognized as one of the world's leading international arbitration practices. With strategic locations in the United States, Europe, Asia and the Middle East, Fulbright is positioned to handle international arbitration disputes wherever they may arise. A record of obtaining successful outcomes in major arbitrations involving a variety of governing laws, jurisdictions and arbitral rules has lead Fulbright to be selected as a leading law firm in the field of international arbitration by the 2008 Chambers Global Guide and one of the top ten arbitration firms worldwide based on total number of arbitrations by the 2007 ALM Focus Europe. Fulbright was the recipient of LatinLawyer Magazine's Deal of the Year: Disputes Category for 2007. The firm's multi-national team of arbitration lawyers is fluent in more than a dozen languages and is experienced in appearing as advocates before arbitrators from a wide range of cultural backgrounds under the rules of all of the major international arbitration institutions. Clients around the world have called on us for some of the most politically charged and high-stakes disputes of recent years, in the public and private sectors. www.fulbright.com www.fulbright.com/
  • KPMG LLP

    KPMG LLP
    www.kpmg.com/us/en/pages/default.asp
  • Miller & Chevalier

    Miller & Chevalier
    www.millerchevalier.com/
  • Pricewaterhousecoopers Llp

    Pricewaterhousecoopers Llp
    www.pwc.com/us/en/index.jhtml
  • Thompson & Knight LLP

    Thompson & Knight LLP
    www.tklaw.com/
  • Vinson & Elkins logo
    Vinson & Elkins
    Innovation is the lifeblood of industries worldwide. At Vinson & Elkins LLP, our lawyers work closely with innovative technology companies, as well as many of the most active venture funds, private equity firms and investment banks. In today's increasingly competitive business environment, the strength of a company's business decisions and IP portfolio often make the difference between success and failure. We counsel our clients on perfecting and protecting key technology patents, trademarks, copyrights and trade secrets and tirelessly advocate clients' interests in complex technology patent, copyright, trademark, trade secret and related IP litigation at both the trial and appellate levels. www.vinson-elkins.com www.vinson-elkins.com/
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