Overview

Join leading 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 13th Biennial Parker C. Fielder Oil and Gas Tax Conference.

This nationally recognized event is a unique collaboration between The University of Texas School of Law and the Chief Counsel’s Office of the IRS, and provides an exchange of views and perspectives between private sector and the Service.

The 2015 program opens with an analysis of Distress in the Energy Industry—factors that led to the current downturn, an overview of the current markets, and the short-term and long-term implications on the industry and the U.S. economy—and continues with a sophisticated array of presentations, panels, and discussions on current energy taxation issues:

  • Keynote Presentation by IRS Chief Counsel William J. Wilkins on Current Issues in Tax Administration
  • In depth discussion on Capital Cost Recovery
  • A look at the use of Farmouts in an Era of Low Oil Prices
  • Domestic tax issues evaluation and discussion: Oil and Gas Tax Fundamentals, plus oil and gas Property and Sale Transactions
  • International tax issues evaluation and discussion: International Tax Issues for the General Practitioner; Transfer Pricing; and Foreign Tax Credit Developments
  • An understanding of the unique property and tax issues in fracking
  • An analysis of Publicly Traded Vehicles for the Energy Industry, including MLPs, Yield Cos, and more
  • Current Issues, pitfalls and best practices involving audits and controversies for taxpayers in the oil and gas industry
  • 1 hour Ethics on recent developments in the area of the regulation of tax practice and tax ethics
  • Special awards presentation honoring William J. Wilkins of the Internal Revenue Service, John T. Bradford of Liskow & Lewis, and Robert A. Sweich of KPMG, for their outstanding service and achievement in oil and gas taxation
If your work involves energy taxation law or finance, don’t miss this exceptional educational and networking event.

Event Schedule

Program is subject to change.

  • Time
    Credit
    Subject
    Speaker
  • Thursday Morning, Nov. 19, 2015
    Presiding Officer:
    Phillip L. Mann, Miller & Chevalier Chartered - Washington, DC
  • 7:30 am
    Registration Opens
    Includes continental breakfast.

  • 8:20 am
    Welcoming Remarks

  • 8:30 am
    0.75 hr
    Distress in the Energy Industry
    A look at factors that led to the downturn and an overview of the current markets. Understand the long and short-term implications of the downturn on the energy industry and the larger U.S. economy, plus gain insights on how companies, lenders and potential investors are responding.   

    Loretta Cross, Stout Risius Ross Inc. - Houston, TX

  • 9:15 am
    1.25 hrs
    Capital Cost Recovery
    A discussion of current cost recovery and accounting issues which may include G&G expenses, IDC costs, intangible drilling costs and offshore operations, the tax consequences of the FASB-IASB Revised Revenue Recognition Standard for oil and gas companies, recent IRS guidance on accounting method changes, and other selected issues.

    Moderator:
    Thomas L. Evans, Kirkland & Ellis LLP - Chicago, IL
    Panelists:
    Stephen E. Comstock, American Petroleum Institute - Washington, DC
    Carol Conjura, KPMG LLP - Washington, DC
    Scott K. Dinwiddie, Internal Revenue Service - Washington, DC
    John F. Eiman, Internal Revenue Service - Houston, TX
    Nancy Piwonka, Marathon Oil Company - Houston, TX

  • 10:30 am
    Break

  • 10:45 am
    1.25 hrs
    Current International Tax Issues for the General Tax Practitioner
    Have you ever wondered what an inversion is? What is BEPS? And what is the difference between a territorial system and a worldwide system? Why are companies and the IRS concerned about transfer pricing? What new reporting regimes will apply to multinational companies? Gain insight on these topics and more, including a high level overview of the most significant international tax topics of the day.

    Moderator:
    Carol P. Tello, Sutherland Asbill & Brennan LLP - Washington, DC
    Panelists:
    David C. Cole, Vinson & Elkins LLP - Houston, TX
    Anne Devereaux, Internal Revenue Service - Washington, DC
    Kevin L. Kenworthy, Miller & Chevalier Chartered - Washington, DC

  • 12:00 pm
    Adjourn to Optional Luncheon
    Included in registration.

  • Thursday Afternoon, Nov. 19, 2015
    Presiding Officer:
    Jeff Wright, Deloitte Tax LLP - Houston, TX
  • 12:45 pm
    Parker Fielder Awards Presentation
    -----
    Presenters:
    John S. Dzienkowski, The University of Texas School of Law, Austin, TX
    Robert J. Peroni, The University of Texas School of Law, Austin, TX
    -----
    Award Recipients:
    John T. Bradford, Liskow & Lewis, Houston, TX
    Robert A. Swiech, KPMG LLP, Houston, TX
    William J. Wilkins, Internal Revenue Service, Washington, DC

  • KEYNOTE LUNCHEON PRESENTATION
    Introduction by C. Elizabeth Wagner, Internal Revenue Service, Washington, DC

  • 1:00 pm
    0.50 hr
    Current Issues in Tax Administration
    An update on significant guidance, litigation, and tax administration issues under discussion at IRS headquarters.

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

  • 1:30 pm
    Break

  • 1:45 pm
    1.25 hrs
    Farmouts in an Era of Low Oil Prices 
    Over the last ten years, the oil and gas industry has experienced an environment of high commodity prices, complex geology, high-tech drilling, and lease provisions with stringent obligations imposed on the operator. Hear about the use of farmouts as a dual financing technique to fund drilling costs and preserve the lease where drilling or production is a condition to holding the mineral rights (or renewing the lease). Furthermore, non-traditional lenders, such as private equity and service companies, are willing to earn mineral interests for their own reasons and will step into the role of farmee. Can the farmout agreement serve as an alternative currency in the new low commodity price environment to get the deal done on a handshake without money changing hands?

    Moderator:
    James D. Reardon, Porter Hedges LLP - Houston, TX
    Panelists:
    Christopher Bryant, Statoil E&P Americas - Houston, TX
    Amy Sutton, Deloitte Tax LLP - Houston, TX
    Clifford M. Warren, Internal Revenue Service - Washington, DC
    Todd Way, Vinson & Elkins LLP - Dallas, TX

  • 3:00 pm
    Break

  • Track A: Domestic Tax Issues
    Presiding Officer:
    R. Richard Coston, Norton Rose Fulbright - Houston, TX
  • 3:15 pm
    1.25 hrs
    Back to Basics: Oil and Gas Tax Fundamentals
    An exploration of oil and gas tax basics including the concept of economic interest, the pool of capital doctrine, G&G, IDC, depletion, production payments and application of like kind exchanges in oil and gas transactions.

    Moderator:
    Denney L. Wright, Exxon Mobil Corporation - Houston, TX
    Panelists:
    David B. Cubeta, Miller & Chevalier Chartered - Washington, DC
    Thomas M. Rathgeb, Shell Oil Company - Houston, TX
    Philip Tiegerman, Internal Revenue Service - Washington, DC
    Bret Wells, University of Houston Law Center - Houston, TX

  • 4:30 pm
    1.25 hrs
    Purchase and Sale Transactions
    Using the federal and state tax provisions from a publicly-available purchase and sale agreement, the panel illustrates the tax issues present in an oil and gas property purchase and sale. Those issues include the allocation of purchase price among the various oil and gas properties, any equipment on those properties, any G&G acquired or other assets, and other uses in the agreement for the allocations; the determination of the amount realized on the purchase and sale when the effective date and closing date are different; representations and warranties in the purchase and sale agreement regarding payment of taxes; allocation of tax responsibility for state and local taxes such as ad valorem tax and sales tax; and purchases and sales involving properties that are held in tax partnerships.

    Moderator:
    John T. Bradford, Liskow & Lewis - Houston, TX
    Panelists:
    Maria T. Collman, PwC - Houston, TX
    Robert A. Jacobson, Bracewell & Giuliani LLP - Houston, TX
    Clifford M. Warren, Internal Revenue Service - Washington, DC
    Catherine Lueck Zabel, Marathon Oil Company - Houston, TX

  • Track B: International Tax Issues
    Presiding Officer:
    Bobby Marandi, PwC - Houston, TX
  • 3:15 pm
    1.25 hrs
    Transfer Pricing Enforcement and Defense
    A discussion of the U.S. transfer pricing enforcement environment with respect to the oil and gas industry, including current IRS initiatives, litigation, and recent APA and competent authority experience; plus an examination of the transfer pricing issues affected by the OECD BEPS project, with special focus on intangibles as well as country-by-country reporting and taxpayer efforts that comply and defend transfer pricing determinations in this environment.

    Moderator:
    Steven C. Wrappe, KPMG LLP - Washington, DC
    Panelists:
    John C. Hughes, Internal Revenue Service - Washington, DC
    Paul M. Schmidt, BakerHostetler - Washington, DC
    Andrew S. Sliwa, Ernst & Young LLP - Chicago, IL
    Kathrin Zoeller, Weatherford - Houston, TX

  • 4:30 pm
    1.25 hrs
    Foreign Tax Credit Developments 
    A discussion and analysis of key foreign tax credit issues affecting the oil and gas industry, including ODLs and the effect of changing from deducting to crediting foreign taxes (and the resulting impact on the availability of credit), current foreign tax credit guidance, and more.

    Moderator:
    Ujwala (UJ) Bhandari, Former Director of Tax, Tenaris - Houston, TX
    Panelists:
    Richard Chewning, Internal Revenue Service - Washington, DC
    David E. Coe, Chevron Services Company - Houston, TX
    John Fiorito, Ernst and Young, LLP - Houston, TX
    Edward C. Osterberg Jr., Mayer Brown LLP - Houston, TX

  • 5:45 pm
    Adjourn to Optional Reception
    Included in registration.

    RECEPTION SPONSORS*
    Andrews Kurth LLP
    Baker Botts
    BakerHostetler
    Bracewell & Giuliani LLP
    Caplin & Drysdale, Chartered
    Chamberlain, Hrdlicka, White, Williams & Aughtry
    Deloitte Tax LLP
    Ernst & Young, LLP
    KPMG LLP
    Latham & Watkins LLP
    Liskow & Lewis
    Mayer Brown LLP 
    Miller & Chevalier Chartered
    Norton Rose Fulbright
    Porter Hedges LLP 
    PwC
    Sidley Austin LLP
    Sutherland Asbill & Brennan 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, Nov. 20, 2015
    Presiding Officer:
    Deborah L. Byers, Ernst & Young LLP - Houston, TX
  • 7:30 am
    Conference Room Opens
    Includes continental breakfast.

  • 8:00 am
    0.75 hr
    Property and Tax Issues in Fracking
    A look at how current property and tax law for oil and gas operations is being applied (or not) to nonconventional horizontal drilling, including property access issues, the application of section 614, and more. What are tax practitioners thinking about, and wrestling with, in applying existing law to this new technology?

    Moderator:
    Todd Keator, Thompson & Knight LLP - Dallas, TX
    Panelists:
    Diane M. Jenkins, XTO Energy Inc. - Fort Worth, TX
    Ted McElroy, Deloitte Tax LLP - Houston, TX

  • 8:45 am
    1.00 hr ethics
    Ch-ch-ch-changes, Turn and Face the Strange Times in Regulating Tax Practitioners 
    An examination and discussion of recent developments in the regulation of tax practice and tax ethics, including scope of Circular 230, privilege/confidentiality and whistleblowing, among others.

    Linda Galler, Maurice A. Deane School of Law at Hofstra University - Hempstead, NY
    Kathryn F. Patterson, Internal Revenue Service - Houston, TX
    Christopher S. Rizek, Caplin & Drysdale, Chartered - Washington, DC

  • 9:45 am
    Break

  • 10:00 am
    1.25 hrs
    Publicly Traded Vehicles for the Energy Industry
    An analysis of various publicly traded vehicles used in the energy industry for raising capital, including master limited partnerships (MLPs), royalty trusts, yieldcos and Up-Cs, and their similarities and differences from a tax perspective. Certain alternative investment types, such as mutual funds, exchange traded funds and exchange traded notes are also addressed. 

    Moderator:
    Timothy J. Devetski, Sidley Austin LLP - Houston, TX
    Panelists:
    Robert Baldwin, PwC - Dallas, TX
    C. Timothy Fenn, Latham & Watkins LLP - Houston, TX
    Caroline Hay, Internal Revenue Service - Washington, DC
    Jordan H. Mintz, Kinder Morgan, Inc. - Houston, TX
    Bill H. Wilson Jr., Internal Revenue Service - Washington, DC

  • 11:15 am
    1.25 hrs
    Redesigning How The IRS Audits Multinationals
    A discussion of LB&I’s programmatic changes to how it conducts audits, control and coordination of international examination issues, recent changes to audit procedures, and cutting edge technologies the IRS employs in conducting audits of oil and gas companies.

    Moderator:
    Peter A. Lowy, Chamberlain, Hrdlicka, White, Williams & Aughtry - Houston, TX
    Panelists:
    Paul R. Antebi, Chevron Corporation - San Ramon, CA
    David W. Horton, Internal Revenue Service - Houston, TX
    Richard A. Husseini, Baker Botts - Houston, TX
    Robert C. Morris, Norton Rose Fulbright - Houston, TX
    Doug O' Donnell, Internal Revenue Service - Houston, TX

  • 12:30 pm
    Adjourn

Conference Faculty

Paul R. Antebi

Chevron Corporation
San Ramon, CA

Robert Baldwin

PwC
Dallas, TX

Ujwala (UJ) Bhandari

Former Director of Tax, Tenaris
Houston, TX

John T. Bradford

Liskow & Lewis
Houston, TX

Christopher Bryant

Statoil E&P Americas
Houston, TX

Richard Chewning

Internal Revenue Service
Washington, DC

David E. Coe

Chevron Services Company
Houston, TX

David C. Cole

Vinson & Elkins LLP
Houston, TX

Maria T. Collman

PwC
Houston, TX

Stephen E. Comstock

American Petroleum Institute
Washington, DC

Carol Conjura

KPMG LLP
Washington, DC

Loretta Cross

Stout Risius Ross Inc.
Houston, TX

David B. Cubeta

Miller & Chevalier Chartered
Washington, DC

Anne Devereaux

Internal Revenue Service
Washington, DC

Timothy J. Devetski

Sidley Austin LLP
Houston, TX

Scott K. Dinwiddie

Internal Revenue Service
Washington, DC

John F. Eiman

Internal Revenue Service
Houston, TX

Thomas L. Evans

Kirkland & Ellis LLP
Chicago, IL

C. Timothy Fenn

Latham & Watkins LLP
Houston, TX

John Fiorito

Ernst and Young, LLP
Houston, TX

Linda Galler

Maurice A. Deane School of Law at Hofstra University
Hempstead, NY

Caroline Hay

Internal Revenue Service
Washington, DC

David W. Horton

Internal Revenue Service
Houston, TX

John C. Hughes

Internal Revenue Service
Washington, DC

Richard A. Husseini

Baker Botts
Houston, TX

Robert A. Jacobson

Bracewell & Giuliani LLP
Houston, TX

Diane M. Jenkins

XTO Energy Inc.
Fort Worth, TX

Todd Keator

Thompson & Knight LLP
Dallas, TX

Kevin L. Kenworthy

Miller & Chevalier Chartered
Washington, DC

Peter A. Lowy

Chamberlain, Hrdlicka, White, Williams & Aughtry
Houston, TX

Ted McElroy

Deloitte Tax LLP
Houston, TX

Jordan H. Mintz

Kinder Morgan, Inc.
Houston, TX

Robert C. Morris

Norton Rose Fulbright
Houston, TX

Doug O' Donnell

Internal Revenue Service
Houston, TX

Edward C. Osterberg Jr.

Mayer Brown LLP
Houston, TX

Kathryn F. Patterson

Internal Revenue Service
Houston, TX

Nancy Piwonka

Marathon Oil Company
Houston, TX

Thomas M. Rathgeb

Shell Oil Company
Houston, TX

James D. Reardon

Porter Hedges LLP
Houston, TX

Christopher S. Rizek

Caplin & Drysdale, Chartered
Washington, DC

Paul M. Schmidt

BakerHostetler
Washington, DC

Andrew S. Sliwa

Ernst & Young LLP
Chicago, IL

Amy Sutton

Deloitte Tax LLP
Houston, TX

Carol P. Tello

Sutherland Asbill & Brennan LLP
Washington, DC

Philip Tiegerman

Internal Revenue Service
Washington, DC

Clifford M. Warren

Internal Revenue Service
Washington, DC

Todd Way

Vinson & Elkins LLP
Dallas, TX

Bret Wells

University of Houston Law Center
Houston, TX

William J. Wilkins

Internal Revenue Service
Washington, DC

Bill H. Wilson Jr.

Internal Revenue Service
Washington, DC

Steven C. Wrappe

KPMG LLP
Washington, DC

Denney L. Wright

Exxon Mobil Corporation
Houston, TX

Catherine Lueck Zabel

Marathon Oil Company
Houston, TX

Kathrin Zoeller

Weatherford
Houston, TX

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

Jennifer Bernardini

Internal Revenue Service
Washington, DC

John T. Bradford

Liskow & Lewis
Houston, TX

Deborah L. Byers

Ernst & Young LLP
Houston, TX

Stephen E. Comstock

American Petroleum Institute
Washington, DC

R. Richard Coston

Norton Rose Fulbright
Houston, TX

Thomas Crichton IV

Vinson & Elkins LLP
Dallas, TX

Heather B. Crowder

ConocoPhillips
Houston, TX

David B. Cubeta

Miller & Chevalier Chartered
Washington, DC

Anne Devereaux

Internal Revenue Service
Washington, DC

Timothy J. Devetski

Sidley Austin LLP
Houston, TX

John F. Eiman

Internal Revenue Service
Houston, TX

Michael J. Esposito

The University of Texas Law Energy Center
Austin, TX

Thomas L. Evans

Kirkland & Ellis LLP
Chicago, IL

Barbara B. Franklin

Internal Revenue Service
Houston, TX

Kenny Hawsey

PwC
Houston, TX

Richard A. Husseini

Baker Botts
Houston, TX

Joanna Jefferson

The University of Texas School of Law
Austin, TX

Eileen E. Johnson

Internal Revenue Service
Houston, TX

Michael L Johnston

KKR
Houston, TX

Todd Keator

Thompson & Knight LLP
Dallas, TX

Kevin L. Kenworthy

Miller & Chevalier Chartered
Washington, DC

Andrius R. Kontrimas

Norton Rose Fulbright
Houston, TX

Paul Kugler

KPMG LLP
Washington, DC

Peter A. Lowy

Chamberlain, Hrdlicka, White, Williams & Aughtry
Houston, TX

C. Ellen MacNeil

Andersen Tax
McLean, VA

Aric Mann

Anadarko Petroleum Corporation
The Woodlands, TX

Phillip L. Mann

Miller & Chevalier Chartered
Washington, DC

Bobby Marandi

PwC
Houston, TX

Edward C. Osterberg Jr.

Mayer Brown LLP
Houston, TX

Jaime Park

Internal Revenue Service
Washington, DC

Kathryn F. Patterson

Internal Revenue Service
Houston, TX

Ralph B. Portell Jr.

BP America
Houston, TX

Tim C. Raymond

Exxon Mobil
Houston, TX

James D. Reardon

Porter Hedges LLP
Houston, TX

Kathy J. Robbins

Internal Revenue Service
Houston, TX

Paul M. Schmidt

BakerHostetler
Washington, DC

Rochelle S. Seade

Chevron Services Company
Houston, TX

Andrew S. Sliwa

Ernst & Young LLP
Chicago, IL

Gregory J. Smith

The University of Texas School of Law
Austin, TX

Robert A. Swiech

KPMG LLP
Houston, TX

Carol P. Tello

Sutherland Asbill & Brennan LLP
Washington, DC

C. Elizabeth Wagner

Internal Revenue Service
Washington, DC

Todd Way

Vinson & Elkins LLP
Dallas, TX

Steven C. Wrappe

KPMG LLP
Washington, DC

Denney L. Wright

Exxon Mobil Corporation
Houston, TX

Jeff Wright

Deloitte Tax LLP
Houston, TX

Credit Info

MCLE Credit
A Texas MCLE Reporting Form will be included in your course materials. Please complete and return to the registration desk and UT Law CLE will report credit on your behalf to the State Bar of Texas, or you can self-report your credit directly to the State Bar of Texas at texasbar.com. A Certificate of Attendance will be provided at the conference to keep for your records.  
At the conference, you will need to sign in on the Record of Attendance form at the registration desk. Self-report your CLE credit directly to the State Bar of California at calbar.ca.gov. You will receive a Certificate of Attendance at the conference to keep for your records. UT Law CLE will maintain Attendance Records for four years.  
At the conference, you will need to sign in on the Record of Attendance form at the registration desk. UT Law CLE will report credit on your behalf to the Supreme Court of Louisiana Continuing Legal Education Committee within 30 days after the conference. You will receive a Certificate of Attendance at the conference to keep for your records.
At the conference, you will need to sign in on the Record of Attendance form at the registration desk. You will receive a Certificate of Attendance at the conference to keep for your records. UT Law CLE will report credit on your behalf to the Oklahoma Bar Association within 30 days after the conference.
Note on Self-Reporting Your Credits in Another State
If you wish to satisfy MCLE or other professional education requirements in another state for a program offered by the University of Texas School of Law, please check with the state bar or other licensing authority in that state before taking the program to ensure it will qualify for self-reporting your credits.
Other Credit
The University of Texas School of Law is an IRS Approved Continuing Education (CE) Provider for Return Preparers and Enrolled Agents. Attendees claiming IRS CE credit must sign in with your Preparer Tax Identification Number (PTIN) to verify attendance. Attendance sign-in sheets will be available at the registration desk. A Certificate of Completion with the program number will be provided at the conclusion of the conference to keep for your records.

Reporting: UT Law will report credit to the IRS on your behalf. For programs that occur during the first nine months of the year, credit will be reported on a quarterly basis (by March 31, June 30, and September 30). For programs that occur during the fourth quarter (October 1 - December 31), credit will be reported within ten (10) days of the last day of the conference. UT Law CLE will maintain Attendance Records for four years.
The University of Texas School of Law is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Delivery Method: Group-Live

To comply with NASBA Standards, attendees claiming CPE credit must sign in to verify attendance for each segment. Attendance sign-in sheets will be available at the registration desk. You will need your CPA license number to sign in. A CPE Certificate of Completion will be provided at the conclusion of the conference.

Reporting: CPAs are responsible for reporting CPE credits earned to their state's accountancy board, and must retain appropriate documentation of their participation in learning activities. Visit your state’s reporting website for more information or www.nasba.org.

Key Dates

Houston – Nov 19-20, 2015 – Hyatt Regency
Conference Concluded
Buy
Houston
Last day for Individual early registration: Nov 13, 2015

Add $50 for registrations received after this time

Last day for Group (5 registrants minimum) early registration: Nov 13, 2015

Add $50 for registrations received after this time

Last day for Group (10 registrants minimum) early registration: Nov 13, 2015

Add $50 for registrations received after this time

Last day for cancellation (full refund): Nov 13, 2015

$50 processing fee applied after this date

Last day for cancellation: Nov 16, 2015

Venue

speaker

1200 Louisiana Street
Houston, TX
713-654-1234

Accommodations

$199 room rate good through October 19, 2015 (subject to availability). 
Reservations must be made online to secure the room rate. 
 

Parking Information

Daily event valet parking:  $12
Overnight parking: $32

Our Sponsors

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

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