16^th Biennial Parker C. Fielder

Oil, Gas, and Energy Tax Conference

A unique forum for discussion between the IRS and private sector on current oil, gas and energy taxation issues

PRESENTED BY
The University of Texas School of Law
The Office of Chief Counsel, Internal Revenue Service

Houston Nov 16-17, 2023 JW Marriott Houston by The Galleria
Conference Concluded

Buy

Related products: eConference Materials

RECEPTION SPONSORS*
Caplin & Drysdale
Chamberlain, Hrdlicka, White, Williams & Aughtry, P.C.
Deloitte Tax LLP
Eversheds Sutherland
Gibson, Dunn & Crutcher LLP
Kirkland & Ellis LLP
KPMG
Latham & Watkins LLP
Liskow
Miller & Chevalier Chartered
Norton Rose Fulbright
Porter Hedges LLP
Vinson & Elkins LLP
Whitley Penn

*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.

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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 16th Biennial Parker C. Fielder Oil, Gas, and Energy 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 2023 program features a sophisticated array of presentations, panels, and discussions on current energy industry and taxation issues, including:

Keynote Presentation by IRS LB&I Deputy Commissioner, Douglas W. O’Donnell
An overview of current issues in the energy sector—where are we now and where might we be headed?
An examination of current energy deals, deal structures, and transactional considerations
A discussion on IRS examinations and interaction between the industry and the government
Concurrent Tracks focused on hot topics in Oil and Gas Taxation or in the Energy Transition space

Don’t miss the chance to hear directly from nationally recognized experts and key personnel at the IRS on multiple taxation issues impacting the oil, gas, and energy industry.

Event Schedule

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

Day 1 November 16, 2023
Day 2 November 17, 2023

Time

Credit

Subject

Speaker
Thursday Morning, Nov. 16, 2023
Presiding Officer:
Kevin L. Kenworthy, Miller & Chevalier Chartered - Washington, DC
8:00 am

Registration Opens

Includes continental breakfast.
8:50 am

Welcoming Remarks
9:00 am

0.75 hr

Current Issues in the Energy Sector

A comprehensive review of the near/medium-term outlook for the energy sector including the energy capital cycle, oil and natural gas dynamics, the decarbonization/energy transition megatrend, the energy investing landscape, and the capital/M&A environment.

Kevin Pollard, Managing Director, Pickering Energy Partners - Houston, TX
9:45 am

1.25 hrs

An Energy Transactions Smorgasbord: Updates on Transaction Structures for Oil and Gas, Renewable and Clean Energy, and Battery Storage

Hear updates on transaction structures for oil and gas mergers and acquisitions and joint development projects as well as wind, solar, hydrogen and battery storage projects after the Inflation Reduction Act. In addition, explore the impact of renewable and clean energy tax credits and their transferability on these structures.

Moderator:
John T. Bradford, Liskow & Lewis - Houston, TX
Panelists:
David Burton, Norton Rose Fulbright - New York, NY
Mitra Ghaemmaghami, Ernst & Young, LLP - Houston, TX
Glenn Leishner, TotalEnergies - Houston, TX
James D. Reardon, Porter Hedges LLP - Houston, TX
11:00 am

15-Minute Break
11:15 am

1.00 hr

What the General Practitioner Should Know about International Tax Practice

High-level descriptions of the most topical issues involving international tax including fundamentals, issue-spotting pointers, and the latest news.

Moderator:
Anne Devereaux, Gibson, Dunn & Crutcher LLP - Los Angeles, CA
Panelists:
Megan J. Hickman, IRS Office of Chief Counsel - Washington, DC
Quyen Huynh, KPMG LLP - Irvine, CA
Kevin L. Kenworthy, Miller & Chevalier Chartered - Washington, DC
12:15 pm

Pick Up Lunch

Included in registration.
Thursday Afternoon, Nov. 16, 2023
Presiding Officer:
R. Richard Coston, Norton Rose Fulbright - Houston, TX
1:00 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
-----
Parker Fielder Award Recipients:
Peter A. Lowy, Chamberlain Hrdlicka, Houston, TX
Douglas W. O'Donnell, Internal Revenue Service, Washington, DC
KEYNOTE LUNCHEON PRESENTATION

Introduction by C. Elizabeth Wagner, Internal Revenue Service, Washington, DC
1:15 pm

0.50 hr

Tax Administration: IRS Deputy Commissioner’s Perspective

Current state of IRS Transformation and the Service & Enforcement impact upon taxpayers and tax professionals.

Douglas W. O'Donnell, Deputy Commissioner, Services & Enforcement, Internal Revenue Service - Washington, DC
Moderator:
Nikole Flax, PwC - Washington, DC
1:45 pm

15-Minute Break
2:00 pm

1.25 hrs

Strategies and Lessons Learned: Opportunities under the IRA

Focus on opportunities under the IRA, including as a result of guidance issued under the IRA, and how companies both in and out of the energy sector are taking advantage of those opportunities.

Moderator:
Amish M. Shah, Holland & Knight LLP - Washington, DC
Panelists:
Lauren A. Collins, Vinson & Elkins LLP - Los Angeles, CA
James A. Holmes, IRS Office of Chief Counsel - Washington, DC
Kate Mathieu, Skadden, Arps, Slate, Meagher & Flom LLP - Washington, DC
Jonathan Storms, Andersen - Houston, TX
3:15 pm

Break into Tracks
TRACK A: Oil & Gas
Presiding Officer:
R. Richard Coston, Norton Rose Fulbright - Houston, TX
3:30 pm

1.00 hr

Energy Excise Taxes – We’re Back, Baby!

From reinstated superfund taxes to recent litigation over energy tax credits and taxation of exported oil, federal excise tax practice in the oil & gas industry is the hottest it’s been in decades. Explore recent developments and the most significant takeaways from a tax compliance and planning perspective.

Moderator:
Peter A. Lowy, Chamberlain Hrdlicka - Houston, TX
Panelists:
Oscar L. Garza, Ryan, LLC - Houston, TX
SaraBeth Smith, Deloitte - Houston, TX
Kimberly Wojcik, U.S. Department of the Treasury - Washington, DC
4:30 pm

15-Minute Break
4:45 pm

1.00 hr

Foreign Tax Credit

Discuss recent developments relating to the foreign tax credit, including creditability of foreign taxes, allocation of foreign taxes, litigation relating to foreign tax credits, and the corporate alternative minimum tax foreign tax credit.

Moderator:
Layla J. Asali, Miller & Chevalier Chartered - Washington, DC
Panelists:
Daniel Barron, Chevron - Houston, TX
David G. Noren, McDermott Will & Emery - Washington, DC
Jeffrey L. Parry, IRS Office of Chief Counsel - Washington, DC
TRACK B: Energy Transition
Presiding Officer:
William Trey Cornelius, Deloitte Tax LLP - Houston, TX
3:30 pm

1.00 hr

Clean Hydrogen, Clean Fuel, and Lifecycle: Understanding the Complexities of 45V and 45Z Credits

Discuss the section 45V clean hydrogen production credit, 45Z clean fuel production credit and recent and expected guidance from Treasury and the IRS. Hear about how these incentives are shaping new green projects and some of the challenges faced by the industry.

Moderator:
Jaime Park, Deloitte - Washington, DC
Panelists:
Michael Q. Cannon, Gibson, Dunn & Crutcher LLP - Dallas, TX
Aindriú Colgan, American Petroleum Institute - Washington, DC
Jason D. Dexter, IRS Office of Chief Counsel - Washington, DC
Sam B. Guthrie, Akin Gump Strauss Hauer & Feld LLP - Washington, DC
4:30 pm

15-Minute Break
4:45 pm

1.00 hr

Section 45Q Credit for Carbon Oxide Sequestration

Focus on the section 45Q tax credit for carbon oxide sequestration, the changes made by the Inflation Reduction Act, and practical insights related to claiming the tax credit.

Moderator:
Julie Chapel, KPMG - Oklahoma City, OK
Panelists:
Joshua L. Belcher, Holland & Knight LLP - Houston, TX
Jennifer Bernardini, U.S. Department of the Treasury - Washington, DC
Jennifer Buchanan, Occidental Petroleum Corporation - Houston, TX
Todd Lowther, Shearman & Sterling - Houston, TX
5:45 pm

Adjourn to Optional Reception

Included in registration.

RECEPTION SPONSORS*
Caplin & Drysdale
Chamberlain, Hrdlicka, White, Williams & Aughtry, P.C.
Deloitte Tax LLP
Eversheds Sutherland
Gibson, Dunn & Crutcher LLP
Kirkland & Ellis LLP
KPMG
Latham & Watkins LLP
Liskow
Miller & Chevalier Chartered
Norton Rose Fulbright
Porter Hedges LLP
Vinson & Elkins LLP
Whitley Penn

*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, 2023
Presiding Officer:
Kathleen M. Kruchten, Internal Revenue Service - Houston, TX
8:00 am

Conference Room Opens

Includes continental breakfast.
8:30 am

1.00 hr ethics

Ethics in Tax Practice

Discuss selected ethical issues that arise for in-house and private practitioners, as well as for government personnel in the tax field, including privilege and confidentiality, conflicts of interests, specific provisions of Circular 230, the ABA Model Rules, the AICPA standards, and related subjects.

Larry A. Campagna, Chamberlain, Hrdlicka, White, Williams & Aughtry, P.C. - Houston, TX
Scott D. Michel, Caplin & Drysdale, Chartered - Washington, DC
R. Scott Shieldes, Internal Revenue Service - Houston, TX
9:30 am

1.00 hr

Monetizing Certain U.S. Tax Credits: Sales and Transfers

With the new Section 6418 rules and recently released proposed regulations, the sale and transfer market for certain U.S. federal income tax credits is expected to grow significantly. Discuss how sales or transfers of credits are and will be effected, applicable terms, risk, and cash flow impacts.

Moderator:
Greg Matlock, Ernst & Young, LLP - Houston, TX
Panelists:
Tracey Baird, Grant Thornton LLP - Houston, TX
Jim Cole, Latham & Watkins LLP - Houston, TX
James A. Holmes, IRS Office of Chief Counsel - Washington, DC
Colin Zelmer, PwC - Palm Beach Gardens, FL
10:30 am

15-Minute Break
10:45 am

1.25 hrs

Partnerships and Pass Through Entities

A discussion of Subchapter K, BBA, and tax administration issues involving partnerships including, the IRS Strategic Operating Plan for passthrough entities; drafting partnership agreements after BBA; acquisitions and responsibility for paying imputed underpayments; issues in electing out of Subchapter K; and Section 1061 issues in oil and gas joint ventures.

Moderator:
Bill Wilson, Whitley Penn, LLP - Plano, TX
Panelists:
Mark Dundon, Kirkland & Ellis LLP - Houston, TX
Joy E. Gerdy Zogby, IRS Office of Chief Counsel - Washington, DC
Robert A. Jacobson, Willkie Farr & Gallagher LLP - Houston, TX
Steven J. Lorch, Bracewell - New York, NY
Clifford R. Scherwinski, Internal Revenue Service - Phoenix, AZ
12:00 pm

1.25 hrs

IRS Examinations, Litigation and Interaction Between Industry and the Government

Explore how the IRS is approaching energy tax issues, affecting both energy transition and more traditional forms of energy. Consider energy provisions of the Inflation Reduction Act as well as longstanding energy tax provisions. Also address how the BBA is affecting audits of companies in the industry and how the new IRS compliance initiatives (supported by additional funding) are impacting the industry.

Moderator:
Richard A. Husseini, Kirkland & Ellis LLP - Houston, TX
Panelists:
David B. Blair, Eversheds Sutherland - Washington, DC
George M. Gerachis, Vinson & Elkins LLP - Houston, TX
Joy E. Gerdy Zogby, IRS Office of Chief Counsel - Washington, DC
Kathleen M. Kruchten, Internal Revenue Service - Houston, TX
Clifford R. Scherwinski, Internal Revenue Service - Phoenix, AZ
1:15 pm

Adjourn

Day 1 November 16, 2023
Day 2 November 17, 2023

Download Schedule

Conference Faculty

Layla J. Asali

Miller & Chevalier Chartered
Washington, DC

Tracey Baird

Grant Thornton LLP
Houston, TX

Daniel Barron

Chevron
Houston, TX

Joshua L. Belcher

Holland & Knight LLP
Houston, TX

Jennifer Bernardini

U.S. Department of the Treasury
Washington, DC

David B. Blair

Eversheds Sutherland
Washington, DC

John T. Bradford

Liskow & Lewis
Houston, TX

Jennifer Buchanan

Occidental Petroleum Corporation
Houston, TX

David Burton

Norton Rose Fulbright
New York, NY

Larry A. Campagna

Chamberlain, Hrdlicka, White, Williams & Aughtry, P.C.
Houston, TX

Michael Q. Cannon

Gibson, Dunn & Crutcher LLP
Dallas, TX

Julie Chapel

KPMG
Oklahoma City, OK

Jim Cole

Latham & Watkins LLP
Houston, TX

Aindriú Colgan

American Petroleum Institute
Washington, DC

Lauren A. Collins

Vinson & Elkins LLP
Los Angeles, CA

Anne Devereaux

Gibson, Dunn & Crutcher LLP
Los Angeles, CA

Jason D. Dexter

IRS Office of Chief Counsel
Washington, DC

Mark Dundon

Kirkland & Ellis LLP
Houston, TX

Nikole Flax

PwC
Washington, DC

Oscar L. Garza

Ryan, LLC
Houston, TX

George M. Gerachis

Vinson & Elkins LLP
Houston, TX

Joy E. Gerdy Zogby

IRS Office of Chief Counsel
Washington, DC

Mitra Ghaemmaghami

Ernst & Young, LLP
Houston, TX

Sam B. Guthrie

Akin Gump Strauss Hauer & Feld LLP
Washington, DC

Megan J. Hickman

IRS Office of Chief Counsel
Washington, DC

James A. Holmes

IRS Office of Chief Counsel
Washington, DC

Richard A. Husseini

Kirkland & Ellis LLP
Houston, TX

Quyen Huynh

KPMG LLP
Irvine, CA

Robert A. Jacobson

Willkie Farr & Gallagher LLP
Houston, TX

Kevin L. Kenworthy

Miller & Chevalier Chartered
Washington, DC

Kathleen M. Kruchten

Internal Revenue Service
Houston, TX

Glenn Leishner

TotalEnergies
Houston, TX

Steven J. Lorch

Bracewell
New York, NY

Todd Lowther

Shearman & Sterling
Houston, TX

Peter A. Lowy

Chamberlain Hrdlicka
Houston, TX

Kate Mathieu

Skadden, Arps, Slate, Meagher & Flom LLP
Washington, DC

Greg Matlock

Ernst & Young, LLP
Houston, TX

Scott D. Michel

Caplin & Drysdale, Chartered
Washington, DC

David G. Noren

McDermott Will & Emery
Washington, DC

Douglas W. O'Donnell

Deputy Commissioner, Services & Enforcement, Internal Revenue Service
Washington, DC

Jaime Park

Deloitte
Washington, DC

Jeffrey L. Parry

IRS Office of Chief Counsel
Washington, DC

Kevin Pollard

Managing Director, Pickering Energy Partners
Houston, TX

James D. Reardon

Porter Hedges LLP
Houston, TX

Clifford R. Scherwinski

Internal Revenue Service
Phoenix, AZ

Amish M. Shah

Holland & Knight LLP
Washington, DC

R. Scott Shieldes

Internal Revenue Service
Houston, TX

SaraBeth Smith

Deloitte
Houston, TX

Jonathan Storms

Andersen
Houston, TX

Bill Wilson

Whitley Penn, LLP
Plano, TX

Kimberly Wojcik

U.S. Department of the Treasury
Washington, DC

Colin Zelmer

PwC
Palm Beach Gardens, FL

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

Joanna Jefferson—Director

The University of Texas School of Law
Austin, TX

Layla J. Asali

Miller & Chevalier Chartered
Washington, DC

Roger J. Benesch

Internal Revenue Service
Fort Worth, TX

Jennifer Bernardini

U.S. Department of the Treasury
Washington, DC

Marc Borella

Internal Revenue Service
Houston, TX

John T. Bradford

Liskow & Lewis
Houston, TX

Julie Chapel

KPMG
Oklahoma City, OK

Jim Cole

Latham & Watkins LLP
Houston, TX

Aindriú Colgan

American Petroleum Institute
Washington, DC

William Trey Cornelius

Deloitte Tax LLP
Houston, TX

R. Richard Coston

Norton Rose Fulbright
Houston, TX

Nicholas J. DeNovio

Latham & Watkins LLP
Washington, DC

Timothy J. Devetski

Ernst & Young LLP
Houston, TX

Mark Dundon

Kirkland & Ellis LLP
Houston, TX

George M. Gerachis

Vinson & Elkins LLP
Houston, TX

Nanette Hamilton

Internal Revenue Service
San Jose, CA

John J. Hemenway

Internal Revenue Service
Houston, TX

Megan J. Hickman

IRS Office of Chief Counsel
Washington, DC

Richard A. Husseini

Kirkland & Ellis LLP
Houston, TX

Robert A. Jacobson

Willkie Farr & Gallagher LLP
Houston, TX

Eileen E. Johnson

Internal Revenue Service
Houston, TX

Joel T. Johnson

ExxonMobil
Houston, TX

Christopher T. Kelley

Internal Revenue Service
Washington, DC

Kevin L. Kenworthy

Miller & Chevalier Chartered
Washington, DC

Kathleen M. Kruchten

Internal Revenue Service
Houston, TX

Glenn Leishner

TotalEnergies
Houston, TX

Todd Lowther

Shearman & Sterling
Houston, TX

Peter A. Lowy

Chamberlain Hrdlicka
Houston, TX

C. Ellen MacNeil

Andersen
McLean, VA

Bobby Marandi

PwC
Houston, TX

Greg Matlock

Ernst & Young, LLP
Houston, TX

Robert C. Morris

Norton Rose Fulbright
Houston, TX

Edward C. Osterberg Jr.

Mayer Brown LLP
Houston, TX

Abdon Rangel

Andersen
Houston, TX

James D. Reardon

Porter Hedges LLP
Houston, TX

Jeff A. Romero

Skadden, Arps, Slate, Meagher & Flom LLP
Houston, TX

Amish M. Shah

Holland & Knight LLP
Washington, DC

Debra Tarr

Internal Revenue Service
Houston, TX

C. Elizabeth Wagner

Internal Revenue Service
Washington, DC

Bill Wilson

Whitley Penn, LLP
Plano, TX

Steven C. Wrappe

Grant Thornton LLP
Washington, DC

Denney L. Wright

The University of Houston Law Center
Houston, TX

Jeff Wright

Deloitte Tax LLP
Houston, TX

Xu Zheng

Internal Revenue Service
Oakland, CA

Credit Info

Houston

MCLE Credit

Texas – 11.25 hrs | 1.00 hrs Ethics
Legal Specialization(s): Administrative Law, Oil, Gas and Mineral Law, Real Estate 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.

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.

Louisiana – 11.25 hrs | 1.00 hrs Ethics

At the completion of the conference you must claim and certify your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. 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.

Oklahoma – 13.50 hrs | 1.00 hrs Ethics

You must claim and certify your credit online in Your Briefcase, then you will then be provided a Certificate of Attendance for your records. UT Law CLE will report credit on your behalf to the Oklahoma Bar Association within 30 days after the conference.

Pennsylvania – 11.00 hrs | 1.00 hrs Ethics

UT Law CLE is an approved provider of Pennsylvania credit, sponsor #236. You must claim your credit online in Your Briefcase, and will then be provided a Certificate of Attendance for your records. Attorney attendance will be reported to Pennsylvania within 2 weeks after credit is claimed and submit. Attorneys are not able to report this credit on their own, and UT Law CLE pays all associated fees for the credit hours. Contact us at accreditation@utcle.org if you have additional questions.

Other States – 11.25 hrs | 1.00 hrs Ethics

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 to ensure it will qualify for self-reporting your credits.

You must claim and certify your credit online in Your Briefcase, you will then be provided a Certificate of Attendance for your records and to provided to other licensing authorities as needed.

MCLE credit is presented based on a 60-minute credit hour.

Other Credit

National Accounting CPE – 13.50 hrs

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 (UT Law CLE is a provider of NASBA Group-Live credit only, which excludes online offerings.

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.

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 – Nov 16-17, 2023 – JW Marriott Houston by The Galleria

Conference Concluded

Buy

Houston

Individual
Last day for $695.00 Regular pricing: Nov 1, 2023

$795.00 for registrations received after this time

In-House Counsel
Last day for $495.00 Regular pricing: Nov 1, 2023

$595.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $625.00 Regular pricing: Nov 1, 2023

$725.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $555.00 Regular pricing: Nov 1, 2023

$655.00 for registrations received after this time

Last day for cancellation (full refund): Nov 10, 2023

$50 processing fee applied after this date

Last day for cancellation: Nov 13, 2023

Venue

JW Marriott Houston by The Galleria

5150 Westheimer Road
Houston, TX
713-961-1500 (reservations)
Map

Accommodations

$209 room rate good through October 25, 2023 (subject to availability). Please mention the "16th Biennial Parker C. Fielder Oil and Gas Tax Conference" when you call the reservations department to receive the discounted rate.

Reservations may also be made online here.

Parking Information

$12 daily self-parking; $29 daily valet parking
$29 overnight self-parking; $49 overnight valet parking
Parking rates are subject to change without notice.

Our Sponsors

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

Caplin & Drysdale

Founded by former IRS commissioner Mortimer Caplin in 1964, Caplin & Drysdale remains a premiere law firm focused on handling highly complex tax issues for corporate multinationals in the United States and abroad. Among our areas of primary focus are international taxation and tax controversies, including counsel and defense in the event of tax audits and other administrative controversies, tax planning advice on compliance with U.S. and foreign transfer pricing rules in connection with ongoing business operations or business transactions, as well as the negotiation of advance pricing agreements between taxpayers, the IRS, and foreign tax authorities. Our ranks include former senior officials from the IRS, the U.S. Treasury, and the Justice Department. Clients can rely on our attorneys' broad knowledge of the tax process and our enduring and productive relationships with tax authorities. Caplin & Drysdale’s substantial technical skill and considerable knowledge on how tax law is made, administered, and applied to specific industries, delivers great value to the firm’s clients.
www.caplindrysdale.com
Chamberlain, Hrdlicka, White, Williams & Aughtry, P.C.

Chamberlain Hrdlicka is a diversified, tax-focused law firm with attorneys providing value at the highest level of client service. We are a mid-market, multi-service firm with a nationally-leading tax practice. While we have grown over the past five decades to more than 160 attorneys with a wide variety of practice areas, personalized attention to our clients’ needs remains a hallmark of our heritage.

We have built our reputation working with established and upcoming businesses as well as entrepreneurs and individuals with sophisticated legal needs. Today, our tradition of personalized service continues to be valued by clients from the smallest start-up ventures to the largest multinational companies.
www.chamberlainlaw.com
Deloitte Tax LLP

Accelerating globalization, growing regulatory and business complexity, and the evolution of tax technology applications are creating ever-increasing expectations for tax executives. At Deloitte, we are leading our clients through this change, helping them to uncover insights and provide long-term strategic value to their organizations.

www.deloitte.com
Eversheds Sutherland

Eversheds Sutherland (US) serves as tax counsel to many of the world’s most prominent companies—including more than one third of the Fortune 100—in every area of federal, international, state and local tax law. Our focus is on helping clients achieve their objectives in a tax-efficient manner and providing them with the highest standard of representation in administrative as well as legal proceedings. Our Tax team is renowned for its in-depth knowledge and experience advising businesses across a range of sectors, including those in oil, gas, power and renewable energy.
https://us.eversheds-sutherland.com/
Gibson, Dunn & Crutcher LLP

Gibson, Dunn & Crutcher LLP is a leading international law firm. Consistently ranking among the world’s top law firms in industry surveys and major publications, Gibson Dunn is distinctively positioned in today’s global marketplace with more than 1,800 lawyers and 20 offices, including Abu Dhabi, Beijing, Brussels, Century City, Dallas, Denver, Dubai, Frankfurt, Hong Kong, Houston, London, Los Angeles, Munich, New York, Orange County, Palo Alto, Paris, San Francisco, Singapore, and Washington, D.C. For more information on Gibson Dunn, please visit our website.
www.gibsondunn.com
Kirkland & Ellis LLP

With a global platform of approximately 3,500 lawyers in 19 cities across the United States, Europe and Asia, Kirkland & Ellis provides elite legal advice and a relentless commitment to client service. Kirkland is a market-leader in each of its core practice areas, including private equity, M&A and other complex corporate transactions; investment fund formation and alternative asset management; restructurings; high-stakes commercial and intellectual property litigation; and government, regulatory and internal investigations. To learn more, please visit www.kirkland.com. www.kirkland.com
KPMG

KPMG is a global network of professional firms providing Audit, Tax, and Advisory services. We trace our origin back to 1897. Our client focus, commitment to excellence, global mind-set, and consistent delivery build trusted relationships that are at the core of our business and reputation. KPMG can help you navigate an unending flow of disruptive forces with confidence. Our seasoned professionals, tax insights, and powerful technology give you the leverage you need to prepare for what’s next and capitalize on new opportunities. We focus on turning knowledge into value through a range of services—from state and local tax to international corporate tax—to help organizations manage costs, improve processes and stay in step with international regulatory requirements.
tax.kpmg.us
Latham & Watkins LLP

As the global energy transition accelerates and markets shift, Latham & Watkins stands out as a powerhouse in the energy sector, skillfully guiding clients through this time of change to take advantage of emerging opportunities. Consistently topping global energy and infrastructure legal adviser league tables, our 600+ global team of energy-focused lawyers spans 14 countries and continues to lead the market in transactional and regulatory work across the energy industry — from oil and gas and conventional power to energy transition and renewables. Latham’s Transactional Tax lawyers have advised on tax issues and structures on some of the largest and most high-profile matters for public and private energy companies, developers, private equity sponsors, and financial institutions. Learn more at www.lw.com/energyandinfrastructure.
www.lw.com/
Liskow

Liskow & Lewis was founded in 1935 and includes nearly 140 lawyers in four offices, strategically located in New Orleans, Lafayette, and Baton Rouge, Louisiana and Houston, Texas. Since its inception, the firm’s practice has focused on the energy and oil and gas industry, and has grown to meet the evolving demands of its clients, diversifying into a wide-ranging litigation and transactional practice across the Gulf Coast. www.liskow.com
Miller & Chevalier Chartered

Miller & Chevalier has been widely recognized as one of the leading tax practices in the United States since its founding more than 100 years ago as the first federal tax practice. The firm has successfully represented many of the world's leading companies with their most complex tax issues. In addition to Tax, the firm has leading practices in Litigation, International Law, Employee Benefits (including ERISA), White Collar Defense and Internal Investigations, and Government Affairs. Miller & Chevalier is proud of its enduring working relationships with many companies in the oil and gas industry and is pleased to be a long standing sponsor of the Parker Fielder Oil, Gas, and Energy Tax Conference. www.millerchevalier.com
Norton Rose Fulbright

Norton Rose Fulbright is a global law firm. We provide the world’s preeminent corporations and financial institutions with a full business law service. We have more than 4,000 lawyers and other legal staff based in Europe, the United States, Canada, Latin America, Asia, Australia, Africa, the Middle East and Central Asia. Recognized for our industry focus, we are strong across all the key industry sectors: financial institutions; energy; infrastructure, mining and commodities; transport; technology and innovation; and life sciences and healthcare. Through our global risk advisory group, we leverage our industry experience with our knowledge of legal, regulatory, compliance and governance issues to provide our clients with practical solutions to the legal and regulatory risks facing their businesses. www.nortonrosefulbright.com
Porter Hedges LLP

Founded in 1981, Porter Hedges is a full-service Houston-based law firm with an office in Oklahoma City. We provide the highest quality work across a range of industries, with particular preeminence in the energy sector. As leading practitioners, we are committed to excellence across our firm and favor an efficient, value-minded approach to serving our clients. We develop practical and integrated solutions to complex challenges that we approach with a business-oriented mindset.

Porter Hedges tax lawyers help businesses, exempt organizations, and individuals plan and achieve their financial objectives while maximizing their tax advantages. We integrate tax planning, transactional assistance, and tax controversy resolution in advising clients on all aspects of federal, state, local, and international taxation. Our tax lawyers regularly assist company owners and executives, chief financial officers, tax directors, bankers, outside accountants, and other advisors in creating sophisticated solutions for complex tax challenges.
www.porterhedges.com
Vinson & Elkins LLP

Vinson & Elkins was founded in 1917 during the emergence of the Texas oil industry. Named the “World’s Leading Energy Law Firm” (Euromoney, 1995–Present)*, V&E assists clients in all facets of the traditional energy and renewable energy industries. Our nationally recognized Tax Practice comprises over 40 attorneys who develop transaction structures and advise on the tax consequences associated with a broad spectrum of transactions, saving tax dollars for our clients while achieving their business goals. We have unparalleled experience in the taxation of energy matters and possess particular experience working with MLPs, complex E&P joint ventures, drillcos, and similar arrangements, as well as parties to tax equity transactions and companies interested in utilizing credits and features offered in the Inflation Reduction Act. We have been ranked Band 1 in Tax in Texas since 2013.

*Based upon the number of lawyers named in the Guide to the World’s Leading Energy & Natural Resource Lawyers
www.velaw.com
Whitley Penn

Whitley Penn is a full-service accounting firm with nine locations and more than 800 employees that delivers services across more than 20 industries. We have consistently been recognized as “One the Top 100 Firms in the U.S.” and “Best of the Best” by INSIDE Public Accounting and other industry publications. Our services include audit, consulting, forensic, litigation, and valuation, risk advisory, tax, transaction advisory, and wealth management.
www.whitleypenn.com

16th Biennial Parker C. Fielder

Oil, Gas, and Energy Tax Conference

A unique forum for discussion between the IRS and private sector on current oil, gas and energy taxation issues PRESENTED BY The University of Texas School of Law The Office of Chief Counsel, Internal Revenue Service

Houston Nov 16-17, 2023 JW Marriott Houston by The Galleria Conference Concluded

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Related products: eConference Materials

Overview

Event Schedule

Thursday Morning, Nov. 16, 2023

Thursday Afternoon, Nov. 16, 2023

Friday Morning, Nov. 17, 2023

Conference Faculty

Layla J. Asali

Tracey Baird

Daniel Barron

Joshua L. Belcher

Jennifer Bernardini

David B. Blair

John T. Bradford

Jennifer Buchanan

David Burton

Larry A. Campagna

Michael Q. Cannon

Julie Chapel

Jim Cole

Aindriú Colgan

Lauren A. Collins

Anne Devereaux

Jason D. Dexter

Mark Dundon

Nikole Flax

Oscar L. Garza

George M. Gerachis

Joy E. Gerdy Zogby

Mitra Ghaemmaghami

Sam B. Guthrie

Megan J. Hickman

James A. Holmes

Richard A. Husseini

Quyen Huynh

Robert A. Jacobson

Kevin L. Kenworthy

Kathleen M. Kruchten

Glenn Leishner

Steven J. Lorch

Todd Lowther

Peter A. Lowy

Kate Mathieu

Greg Matlock

Scott D. Michel

David G. Noren

Douglas W. O'Donnell

Jaime Park

Jeffrey L. Parry

Kevin Pollard

James D. Reardon

Clifford R. Scherwinski

Amish M. Shah

R. Scott Shieldes

SaraBeth Smith

Jonathan Storms

Bill Wilson

Kimberly Wojcik

Colin Zelmer

Planning Committee

John S. Dzienkowski—Co-Chair

Robert J. Peroni—Co-Chair

Joanna Jefferson—Director

Layla J. Asali

Roger J. Benesch

Jennifer Bernardini

Marc Borella

John T. Bradford

Julie Chapel

Jim Cole

Aindriú Colgan

William Trey Cornelius

R. Richard Coston

Nicholas J. DeNovio

Timothy J. Devetski

16^th Biennial Parker C. Fielder

A unique forum for discussion between the IRS and private sector on current oil, gas and energy taxation issues

PRESENTED BY
The University of Texas School of Law
The Office of Chief Counsel, Internal Revenue Service

Houston Nov 16-17, 2023 JW Marriott Houston by The Galleria
Conference Concluded