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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 14th 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 the private sector and the Service. The 2017 program features a sophisticated array of presentations, panels, and discussions on current energy taxation issues, including:

  • An Opening Presentation on The Global Energy Challenge and How the U.S. Fits
  • Keynote Presentation by IRS LB&I Commissioner, Doug O’Donnell
  • In depth discussion on Capital Cost Recovery
  • An analysis of Oil and Gas Investment Vehicles, including price and profitability issues and tax reform issues
  • Select domestic tax issues: Partnership Allocation Issues, plus Tax Issues for Distressed Companies
  • International tax issues: Current Issues in International Tax for the General Practitioner; in-depth discussion of International Tax Planning Issues; and International Compliance
  • Hot Topics in Oil and Gas Tax
  • A discussion on the latest developments and impacts of LB&I’s campaign audit strategy on the energy sector
  • 1 hour Ethics on recent developments in the area of the regulation of tax practice and tax ethics
  • Multiple networking opportunities, including the Thursday Evening Attendee Reception
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. 16, 2017
    Presiding Officer:
    Kimberly A. Edwards, Internal Revenue Service - Oakland, CA
  • 7:30 am
    Registration Opens
    Includes continental breakfast.

  • 8:20 am
    Welcoming Remarks

  • 8:30 am
    0.75 hr
    The Global Energy Challenge and How the U.S. Fits
    The world is faced with the tremendous challenge of providing sufficient energy services to fuel sustained economic growth in an environmentally benign way. This is all realized against a backdrop of shifting global energy trade flows due to rapid economic growth in developing nations and the development of new energy resources. Explore the state of energy today, what may come as the winds of change continue to blow around the world, and how the U.S. fits into the discussion. 

    Kenneth B. Medlock III, James A. Baker III Institute for Public Policy - Houston, TX

  • 9:15 am
    1.50 hrs
    Capital Cost Recovery
    A discussion of current cost recovery and accounting issues which may include geological and geophysical expenses, intangible drilling and development costs, cost depletion, tax consequences of the FASB-IASB Revised Revenue Recognition Standard for oil and gas companies, capital versus repair issues, section 179C, abandonment and worthlessness issues, recent IRS guidance, and other selected issues.

    Moderator:
    Thomas L. Evans, Kirkland & Ellis LLP - Chicago, IL
    Panelists:
    J. Shayne Buchanan, Occidental Petroleum Corporation - Tulsa, OK
    Scott K. Dinwiddie, Internal Revenue Service - Washington, DC
    John F. Eiman, Internal Revenue Service - Houston, TX
    C. Ellen MacNeil, Andersen Tax - Washington, DC
    Bret A. Oliver, PwC - Houston, TX

  • 10:45 am
    Break

  • 11:00 am
    1.00 hr
    Current Issues in International Tax for the General Practitioner
    A layman’s explanation of the international issues that are frequently in newspaper headlines, including “inversions,” “territorial systems,” the border adjustment tax, base erosion, and others that are regularly debated in the press and on the nightly news. Gain knowledge from this high level overview that will allow you to debate the issues with the best of them.

    Moderator:
    Carol P. Tello, Eversheds Sutherland - Washington, DC
    Panelists:
    Anne Devereaux, Deputy Associate Chief Counsel, Internal Revenue Service - Washington, DC
    Kevin L. Kenworthy, Miller & Chevalier Chartered - Washington, DC
    N. Susan Stone, Baker & McKenzie LLP - Houston, TX

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

  • Thursday Afternoon, Nov. 16, 2017
    Presiding Officer:
    David B. Cubeta, Miller & Chevalier Chartered - Washington, DC
  • Phil Mann Remembrance and Dedication
    We dedicate this year's Conference to Phil Mann, whose investment and commitment to this program was instrumental in its success for many years.

  • 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:
    Kenneth Wood, Internal Revenue Service, Washington, DC
    Denney L. Wright, Professor of Practice, The University of Houston Law Center and former ExxonMobil Tax, Houston, TX
     

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

  • 1:00 pm
    0.50 hr
    Tax Administration: LB&I Commissioner’s Perspective
    An update on IRS activities for administering to large and mid-size companies, including relevant domestic and global activities impacting tax administrators, taxpayers and advisors.

    Douglas W. O'Donnell, Commissioner, Large Business & International, Internal Revenue Service - Washington, DC

  • 1:30 pm
    Break

  • 1:45 pm
    1.00 hr
    Oil and Gas Investment Vehicles Revisited
    An analysis of investment vehicles including corporations and partnerships in all of their various forms, with a focus on the price/profitability issues and/or tax reform issues of the day.  

    Moderator:
    Denney L. Wright, Professor of Practice, The University of Houston Law Center - Houston, TX
    Panelists:
    Maria T. Collman, PwC - Houston, TX
    Robert A. Jacobson, Willkie Farr & Gallagher LLP - Houston, TX
    Clifford M. Warren, Internal Revenue Service - Washington, DC

  • 2:45 pm
    Break

  • Track A: Domestic Tax Issues
    Presiding Officer:
    R. Richard Coston, Norton Rose Fulbright - Houston, TX
  • 3:00 pm
    1.25 hrs
    Partnership Allocation Issues: An Analysis of Functional Allocations, Target Allocations and the New Disguised Sale Regulations
    Analyze and discuss how “functional” allocations in the API Model Tax Partnership Agreement and “target” allocations in typical private equity investments impact the after-tax results of partners in oil and gas joint ventures classified as partnerships for tax purposes. In addition, review the impact of the new section 707 Disguised Sale regulations on the structuring of investments in and distributions from such joint ventures.

    Moderator:
    John T. Bradford, Liskow & Lewis - Houston, TX
    Panelists:
    William H. Caudill, Norton Rose Fulbright - Houston, TX
    Timothy J. Devetski, Ernst & Young LLP - Houston, TX
    Michael L Johnston, KKR - Houston, TX
    Clifford M. Warren, Internal Revenue Service - Washington, DC

  • 4:15 pm
    1.25 hrs
    Select Tax Issues for Distressed Companies
    Explore federal income tax issues with respect to restructuring or disposing of oil and gas assets, as well as restructuring or selling oilfield service companies. The discussion includes a look at workouts and bankruptcies involving these businesses, and the tax issues of concern to investors and management teams facing the crisis.

    Moderator:
    James D. Reardon, Porter Hedges LLP - Houston, TX
    Panelists:
    Roger D. Aksamit, Thompson & Knight LLP - Houston, TX
    Glenn Dance, Grant Thornton LLP - Arlington, VA
    Abdon Rangel, Linn Energy, Inc. - Houston, TX
    Howard Tucker, Ernst & Young LLP - New York, NY

  • Track B: International Tax Issues
    Presiding Officer:
    David B. Cubeta, Miller & Chevalier Chartered - Washington, DC
  • 3:00 pm
    1.25 hrs
    International Tax Planning Issues—Evolving in the Face of Uncertainty
    Managing international tax planning, including adoption of a territorial system as part of U.S. tax reform, the accompanying transition issues of repatriation and anti-base erosion rules and increasing tax-avoidance and transfer pricing efforts around the globe. 

    Moderator:
    Heather B. Crowder, Phillips 66 - Houston, TX
    Panelists:
    Edward C. Osterberg Jr., Mayer Brown LLP - Houston, TX
    David Petrick, PwC - Houston, TX
    Moshe Spinowitz, Skadden, Arps, Slate, Meagher & Flom LLP - Boston, MA
    Kenneth Wood, Deputy Associate Chief Counsel (International), Internal Revenue Service - Washington, DC

  • 4:15 pm
    1.25 hrs
    International Compliance 
    A discussion on the new compliance burdens imposed by the OECD’s BEPS project, with focus on the country-by-country disclosure requirements, as well as an analysis of the likely areas of transfer pricing disputes and recommendations for defense of transfer pricing determinations.

    Moderator:
    Steven C. Wrappe, KPMG LLP - Washington, DC
    Panelists:
    John D. Bates, BakerHostetler - Washington, DC
    Brandon Bingham, Deloitte Tax LLP - Houston, TX
    Melinda Harvey, Internal Revenue Service - Washington, DC

  • 5:30 pm
    Adjourn to Optional Reception
    Included in registration.

    RECEPTION SPONSORS*
    Andersen Tax LLC
    Andrews Kurth
    Baker Botts L.L.P.
    BakerHostetler
    Bracewell LLP
    Caplin & Drysdale, Chartered
    Chamberlain, Hrdlicka, White, Williams & Aughtry
    Deloitte Tax LLP
    Ernst & Young LLP
    KPMG LLP
    Liskow & Lewis
    Mayer Brown LLP
    Miller & Chevalier Chartered
    Norton Rose Fulbright
    Porter Hedges LLP
    Skadden, Arps, Slate, Meagher & Flom LLP
    Thompson & Knight LLP
    Vinson & Elkins LLP
    Willkie Farr & Gallagher 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. 17, 2017
    Presiding Officer:
    Robert A. Swiech, KPMG LLP - Houston, TX
  • 7:30 am
    Conference Room Opens
    Includes continental breakfast.

  • 8:00 am
    1.00 hr
    The New Partnership Audit Rules
    The new partnership audit rules are a dramatic departure from the current federal procedures. The new rules raise a number of unanswered questions and also provide partnerships with elective options potentially yielding significantly different results. Hear a summary of the new rules and how taxpayers may revise current partnership agreements, and negotiate partnership transactions, in light of the new rules. 

    Moderator:
    Elizabeth McGinley, Bracewell LLP - New York, NY
    Panelists:
    George Hani, Miller & Chevalier Chartered - Washington, DC
    Holly O. Paz, Large Business & International Division, Internal Revenue Service - Washington, DC

  • 9:00 am
    1.00 hr ethics
    Avoiding Potential Discipline Situations
    Examine the application of Circular 230 and various state ethics rules to common situations encountered by tax professionals in planning, audits and compliance. In connection with each situation, hear ways practitioners can avoid or remedy problems that may arise so that practitioners can stay out of disciplinary trouble. 

    Linda Galler, Maurice A. Deane School of Law at Hofstra University - Hempstead, NY
    Christopher S. Rizek, Caplin & Drysdale, Chartered - Washington, DC

  • 10:00 am
    Break

  • 10:15 am
    1.00 hr
    Hot Topics in Oil and Gas Tax
    Explore a number of recent tax developments and issues pertaining to the oil and gas industry, including marginal well credit developments, Section 199 issues, complexities involving IDCs and AMT preferences, and MLP/qualifying income developments.

    Moderator:
    P. Todd Way, Vinson & Elkins LLP - Dallas, TX
    Panelists:
    Jennifer Bernardini, Office of Chief Counsel, Internal Revenue Service - Washington, DC
    Julie M. Holmes Chapel, Office of Chief Counsel, Internal Revenue Service - Oklahoma City, OK
    Glenn Leishner, Anadarko Petroleum Corporation - The Woodlands, TX
    Allison D. Mantor, Andrews Kurth - Houston, TX
    Ted McElroy, Deloitte Tax LLP - Houston, TX

  • 11:15 am
    1.25 hrs
    Tax Controversy and Audit: The Impact of the New LB&I Campaign Strategy on the Oil and Gas Sector
    Discuss the latest developments in LB&I’s campaign audit strategy, with a focus specifically on impacts of the new audit campaign strategy on the energy sector and the oil and gas sector specifically.

    Moderator:
    Richard A. Husseini, Baker Botts L.L.P. - Houston, TX
    Panelists:
    Mickey G. Culpepper, Baker Hughes, a GE Company - Houston, TX
    Kimberly A. Edwards, Internal Revenue Service - Oakland, CA
    Peter A. Lowy, Chamberlain, Hrdlicka, White, Williams & Aughtry - Houston, TX
    Kathryn F. Patterson, Office of Chief Counsel, Internal Revenue Service - Houston, TX

  • 12:30 pm
    Adjourn

Download Schedule

Conference Faculty

Roger D. Aksamit

Thompson & Knight LLP
Houston, TX

John D. Bates

BakerHostetler
Washington, DC

Jennifer Bernardini

Office of Chief Counsel, Internal Revenue Service
Washington, DC

Brandon Bingham

Deloitte Tax LLP
Houston, TX

John T. Bradford

Liskow & Lewis
Houston, TX

J. Shayne Buchanan

Occidental Petroleum Corporation
Tulsa, OK

William H. Caudill

Norton Rose Fulbright
Houston, TX

Maria T. Collman

PwC
Houston, TX

Heather B. Crowder

Phillips 66
Houston, TX

Mickey G. Culpepper

Baker Hughes, a GE Company
Houston, TX

Glenn Dance

Grant Thornton LLP
Arlington, VA

Anne Devereaux

Deputy Associate Chief Counsel, Internal Revenue Service
Washington, DC

Timothy J. Devetski

Ernst & Young LLP
Houston, TX

Scott K. Dinwiddie

Internal Revenue Service
Washington, DC

Kimberly A. Edwards

Internal Revenue Service
Oakland, CA

John F. Eiman

Internal Revenue Service
Houston, TX

Thomas L. Evans

Kirkland & Ellis LLP
Chicago, IL

Linda Galler

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

George Hani

Miller & Chevalier Chartered
Washington, DC

Melinda Harvey

Internal Revenue Service
Washington, DC

Julie M. Holmes Chapel

Office of Chief Counsel, Internal Revenue Service
Oklahoma City, OK

Richard A. Husseini

Baker Botts L.L.P.
Houston, TX

Robert A. Jacobson

Willkie Farr & Gallagher LLP
Houston, TX

Michael L Johnston

KKR
Houston, TX

Kevin L. Kenworthy

Miller & Chevalier Chartered
Washington, DC

Glenn Leishner

Anadarko Petroleum Corporation
The Woodlands, TX

Peter A. Lowy

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

C. Ellen MacNeil

Andersen Tax
Washington, DC

Allison D. Mantor

Andrews Kurth
Houston, TX

Ted McElroy

Deloitte Tax LLP
Houston, TX

Elizabeth McGinley

Bracewell LLP
New York, NY

Kenneth B. Medlock III

James A. Baker III Institute for Public Policy
Houston, TX

Douglas W. O'Donnell

Commissioner, Large Business & International, Internal Revenue Service
Washington, DC

Bret A. Oliver

PwC
Houston, TX

Edward C. Osterberg Jr.

Mayer Brown LLP
Houston, TX

Kathryn F. Patterson

Office of Chief Counsel, Internal Revenue Service
Houston, TX

Holly O. Paz

Large Business & International Division, Internal Revenue Service
Washington, DC

David Petrick

PwC
Houston, TX

Abdon Rangel

Linn Energy, Inc.
Houston, TX

James D. Reardon

Porter Hedges LLP
Houston, TX

Christopher S. Rizek

Caplin & Drysdale, Chartered
Washington, DC

Moshe Spinowitz

Skadden, Arps, Slate, Meagher & Flom LLP
Boston, MA

N. Susan Stone

Baker & McKenzie LLP
Houston, TX

Carol P. Tello

Eversheds Sutherland
Washington, DC

Howard Tucker

Ernst & Young LLP
New York, NY

Clifford M. Warren

Internal Revenue Service
Washington, DC

P. Todd Way

Vinson & Elkins LLP
Dallas, TX

Kenneth Wood

Deputy Associate Chief Counsel (International), Internal Revenue Service
Washington, DC

Steven C. Wrappe

KPMG LLP
Washington, DC

Denney L. Wright

Professor of Practice, The University of Houston Law Center
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

Office of Chief Counsel, Internal Revenue Service
Washington, DC

John T. Bradford

Liskow & Lewis
Houston, TX

Maria T. Collman

PwC
Houston, TX

Stephen E. Comstock

American Petroleum Institute
Washington, DC

R. Richard Coston

Norton Rose Fulbright
Houston, TX

Kristine A. Crabtree

Internal Revenue Service
Washington, DC

David B. Cubeta

Miller & Chevalier Chartered
Washington, DC

Timothy J. Devetski

Ernst & Young LLP
Houston, TX

Kimberly A. Edwards

Internal Revenue Service
Oakland, CA

John F. Eiman

Internal Revenue Service
Houston, TX

Thomas L. Evans

Kirkland & Ellis LLP
Chicago, IL

Mary J. Greco

Internal Revenue Service
Seattle, WA

Richard A. Husseini

Baker Botts L.L.P.
Houston, TX

Robert A. Jacobson

Willkie Farr & Gallagher LLP
Houston, TX

Joanna Jefferson

The University of Texas School of Law
Austin, TX

Eileen E. Johnson

Internal Revenue Service
Houston, TX

Todd Keator

Thompson & Knight LLP
Dallas, TX

Kevin L. Kenworthy

Miller & Chevalier Chartered
Washington, DC

Patrick Kirwan

Internal Revenue Service
Washington, DC

Andrius R. Kontrimas

Norton Rose Fulbright
Houston, TX

Kathleen Kruchten

Internal Revenue Service
Houston, TX

Glenn Leishner

Anadarko Petroleum Corporation
The Woodlands, TX

Peter A. Lowy

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

Bobby Marandi

PwC
Houston, TX

Gregory M. Matlock

Ernst & Young LLP
Houston, TX

Edward C. Osterberg Jr.

Mayer Brown LLP
Houston, TX

Kathryn F. Patterson

Office of Chief Counsel, Internal Revenue Service
Houston, TX

Tim C. Raymond

Exxon Mobil
Houston, TX

James D. Reardon

Porter Hedges LLP
Houston, TX

Paul M. Schmidt

BakerHostetler
Washington, DC

Rochelle S. Seade

Chevron Services Company
Houston, TX

Robert A. Swiech

KPMG LLP
Houston, TX

Carol P. Tello

Eversheds Sutherland
Washington, DC

C. Elizabeth Wagner

Internal Revenue Service
Washington, DC

P. Todd Way

Vinson & Elkins LLP
Dallas, TX

Kenneth Wood

Deputy Associate Chief Counsel (International), Internal Revenue Service
Washington, DC

Steven C. Wrappe

KPMG LLP
Washington, DC

Denney L. Wright

Professor of Practice, The University of Houston Law Center
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 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.
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 will need to sign in on the Accounting CPE Record of Attendance form at the registration desk. You will receive a Texas Accounting Certificate of Completion at the conference for your records. Self-report your CPE credit directly to TSBPA. UT Law CLE will maintain Attendance Records for four years.  

Contact Laura Tolin, ltolin@law.utexas.edu, if you have additional questions.

Key Dates

Houston – Nov 16-17, 2017 – Royal Sonesta Hotel Houston
Conference Concluded
Buy
Houston
Last day for Individual early registration: Nov 7, 2017

Add $50 for registrations received after this time

Last day for Group (5 registrants minimum) early registration: Nov 7, 2017

Add $50 for registrations received after this time

Last day for Group (10 registrants minimum) early registration: Nov 7, 2017

Add $50 for registrations received after this time

Last day for cancellation (full refund): Nov 10, 2017

$50 processing fee applied after this date

Last day for cancellation: Nov 13, 2017

Venue

speaker

Royal Sonesta Hotel Houston

2222 West Loop South
Houston, TX 77027-3502
713.627.7600
855.463.3091 (reservations)
Map

Accommodations

$179 room rate good through October 27, 2017 (subject to availability). 

Parking Information

$10 daily self-parking; $16 overnight self-parking; $16 valet daily parking; $25.60 valet overnight 

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