2025

Oil, Gas, and Energy Taxation Symposium

A Parker C. Fielder Signature Event

Houston Nov 19, 2025 Clifford Chance, Houston $545 Individual $495 Group rate per person (5 registrants minimum) $445 Group rate per person (10 registrants minimum)

Overview

As the oil, gas, and energy taxation landscape evolves, staying ahead isn’t just about keeping up—it’s about gaining insight, strategy, and professional connections.

This special one-day gathering—a focused program spun off from the renowned Parker C. Fielder Oil, Gas, and Energy Taxation Conference—brings together top minds in oil, gas, and energy taxation to unpack the latest developments and tackle the most pressing issues facing practitioners and companies today. Topics include:

A Look at the State of the Energy Industry
Federal Legislative Updates
Federal Regulatory Updates
Working with the Current IRS: What’s Changed and What Do You Need to Know?
Current Practice Issues and Considerations in Oil and Gas Taxation
Hot Topics: Renewable Energy Tax Credits after the OBBB Act
Trends in Litigation and Controversies

Plus: Don’t miss the Networking Luncheon and Breaks—your chance to connect with leading tax professionals, speakers, and peers in a more relaxed setting.

Event Schedule

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

Time

Credit

Subject

Speaker
Wednesday Morning, Nov. 19, 2025
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

Opening Keynote Presentation: Global Outlook and the View to 2050

Hear ExxonMobil’s view of demand and supply of energy and related products through 2050.

Rosina Chaker, Industry Outlook Manager, ExxonMobil

Rosina Chaker, Industry Outlook Manager, ExxonMobil
9:45 am

1.00 hr

Federal Legislative Update

Discuss the recently enacted One Big Beautiful Bill Act and the prospects for additional tax legislation this year.

Layla J. Asali, Miller & Chevalier Chartered - Washington, DC
Mark Dundon, Kirkland & Ellis LLP - Houston, TX
Jessica Blair Theilken, KPMG LLP - Dallas, TX

Layla J. Asali, Miller & Chevalier Chartered - Washington, DC
Mark Dundon, Kirkland & Ellis LLP - Houston, TX
Jessica Blair Theilken, KPMG LLP - Dallas, TX
10:45 am

15-Minute Break
11:00 am

1.00 hr

Federal Regulatory Update

From the Inflation Reduction Act to the National Environmental Policy Act, discuss the Trump Administration’s rollback of agency regulations and the Supreme Court’s decisions scaling back deference to agency regulations. The President has issued a number of Executive Orders that call for the elimination of obsolete federal regulations, but he has also issued an Executive Order calling for an acceleration of agency guidance under the One Bill Beautiful Bill Act’s tax provisions (“OBBBA”). Outline what federal agencies have done to date to align with the Trump Administration’s agenda. To the extent relevant for energy infrastructure projects and renewable energy tax credits, discuss proposals in Congress to expedite federal agency permitting of large-scale projects, taking into consideration the shortened timeline to qualify for certain renewable energy tax credits under the OBBBA.

William Trey Cornelius, Deloitte Tax LLP - Houston, TX
Jim Reardon, Nelson Mullins Riley & Scarborough LLP - Houston, TX

William Trey Cornelius, Deloitte Tax LLP - Houston, TX
Jim Reardon, Nelson Mullins Riley & Scarborough LLP - Houston, TX
12:00 pm

Networking Luncheon

Included in registration.
Wednesday Afternoon, Nov. 19, 2025
Presiding Officer:
Peter A. Lowy, Nelson Mullins Riley & Scarborough LLP - Houston, TX
1:00 pm

1.00 hr

Working with the Current IRS: What's Changed and What You Need to Know

As the IRS goes through an historic period of transition and change, the challenges for taxpayers and practitioners in seeking to resolve unsettled tax positions are greater than ever. Turnover in leadership and material declines in staffing at the IRS contribute to compounding delays that are a source of frustration for all. In this environment, it is more important than ever to understand the paths available for taxpayers to obtain certainty in their return reporting positions, ranging from opinions and letter rulings on the front end to administrative appeals and litigation on the back end. This session provides an overview of those procedures and discuss ways in which taxpayers can effectively utilize them in the current resource constrained environment.

Michael J. Desmond, Miller & Chevalier Chartered - Washington, DC
Bill Wilson, Whitley Penn, LLP - Plano, TX

Michael J. Desmond, Miller & Chevalier Chartered - Washington, DC
Bill Wilson, Whitley Penn, LLP - Plano, TX
2:00 pm

1.00 hr

Current Issues and Considerations in Oil and Gas Taxation: New Twists on Established Concepts

Examine recent developments in the economic interest concept dealing with the availability of an alternate source of investment recovery. Discuss meeting the requirements for an election out under Section 761 in cases where third-party vendors dispose of hydrocarbon products such as “skim oil” and “drip” condensate on behalf of the producers in a joint operating agreement and where a gas balancing agreement is included in the joint operating agreement. Conclude by addressing certain drafting considerations, including with respect to the “Allocated Values” and Section 1060 allocation schedules to an oil and gas property purchase agreement to optimize the bonus depreciation deduction revitalized by the 2025 One Big Beautiful Bill Act.

John T. Bradford, Liskow & Lewis - Houston, TX
Greg Matlock, Ernst & Young, LLP - Houston, TX
Julia Pashin, Akin Gump Strauss Hauer & Feld LLP - Dallas, TX

John T. Bradford, Liskow & Lewis - Houston, TX
Greg Matlock, Ernst & Young, LLP - Houston, TX
Julia Pashin, Akin Gump Strauss Hauer & Feld LLP - Dallas, TX
3:00 pm

15-Minute Break
3:15 pm

1.00 hr

Hot Topics: Renewable Energy Tax Credits after the OBBB Act

Discuss key issues stemming from recent changes to U.S. renewable energy tax credit programs under the OBBB Act, including Executive Orders and sub-regulatory guidance issued after the OBBB Act was signed into law on July 4, 2025 and how companies have been addressing those issues in the months following the enactment of the OBBB Act.

Julie Chapel, KPMG - Oklahoma City, OK
Todd Lowther, Clifford Chance US LLP - Houston, TX
Amish M. Shah, Holland & Knight LLP - Washington, DC

Julie Chapel, KPMG - Oklahoma City, OK
Todd Lowther, Clifford Chance US LLP - Houston, TX
Amish M. Shah, Holland & Knight LLP - Washington, DC
4:15 pm

1.00 hr

Trends in Litigation and Controversies

Address changes in the federal income tax enforcement environment under the Trump Administration. Discuss the state of partnership audits, both from a substantive and procedural perspective, as well as enforcement targeted at Biden-era “green credits.” In addition, hear the panelists' experiences with the government’s assertion of anti-abuse doctrines and anti-abuse regulations in tax litigation, particularly involving partnership and international issues.

George M. Gerachis, Vinson & Elkins LLP - Houston, TX
Robert C. Morris, Norton Rose Fulbright US LLP - Houston, TX
Leah Davis Patrick, Kirkland & Ellis LLP - Houston, TX

George M. Gerachis, Vinson & Elkins LLP - Houston, TX
Robert C. Morris, Norton Rose Fulbright US LLP - Houston, TX
Leah Davis Patrick, Kirkland & Ellis LLP - Houston, TX
5:15 pm

Adjourn

Download Schedule

Conference Faculty

Layla J. Asali

Miller & Chevalier Chartered
Washington, DC

John T. Bradford

Liskow & Lewis
Houston, TX

Rosina Chaker

Industry Outlook Manager, ExxonMobil

Julie Chapel

KPMG
Oklahoma City, OK

William Trey Cornelius

Deloitte Tax LLP
Houston, TX

Michael J. Desmond

Miller & Chevalier Chartered
Washington, DC

Mark Dundon

Kirkland & Ellis LLP
Houston, TX

George M. Gerachis

Vinson & Elkins LLP
Houston, TX

Todd Lowther

Clifford Chance US LLP
Houston, TX

Greg Matlock

Ernst & Young, LLP
Houston, TX

Robert C. Morris

Norton Rose Fulbright US LLP
Houston, TX

Julia Pashin

Akin Gump Strauss Hauer & Feld LLP
Dallas, TX

Leah Davis Patrick

Kirkland & Ellis LLP
Houston, TX

Jim Reardon

Nelson Mullins Riley & Scarborough LLP
Houston, TX

Amish M. Shah

Holland & Knight LLP
Washington, DC

Jessica Blair Theilken

KPMG LLP
Dallas, TX

Bill Wilson

Whitley Penn, LLP
Plano, TX

Planning Committee

Layla J. Asali

Miller & Chevalier Chartered
Washington, DC

John T. Bradford

Liskow & Lewis
Houston, TX

Julie Chapel

KPMG
Oklahoma City, OK

William Trey Cornelius

Deloitte Tax LLP
Houston, TX

R. Richard Coston

Norton Rose Fulbright US LLP
Houston, TX

Mark Dundon

Kirkland & Ellis LLP
Houston, TX

John S. Dzienkowski

The University of Texas School of Law
Austin, TX

George M. Gerachis

Vinson & Elkins LLP
Houston, TX

Joel T. Johnson

ExxonMobil
Houston, TX

Kevin L. Kenworthy

Miller & Chevalier Chartered
Washington, DC

Todd Lowther

Clifford Chance US LLP
Houston, TX

Peter A. Lowy

Nelson Mullins Riley & Scarborough LLP
Houston, TX

Bobby Marandi

PwC
Houston, TX

Greg Matlock

Ernst & Young, LLP
Houston, TX

Abdon Rangel

Kroll, LLC
Houston, TX

Jim Reardon

Nelson Mullins Riley & Scarborough LLP
Houston, TX

Amish M. Shah

Holland & Knight LLP
Washington, DC

Bill Wilson

Whitley Penn, LLP
Plano, TX

Denney L. Wright

The University of Houston Law Center
Houston, TX

Credit Info

Houston

MCLE Credit

Texas – 6.75 hrs
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.

California – 6.75 hrs

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 – 6.00 hrs

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 – 8.00 hrs

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 – 6.50 hrs

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 – 6.75 hrs

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

TX Accounting CPE – 8.10 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 19, 2025 – Clifford Chance, Houston

Houston

Individual
Last day for $495.00 Regular pricing: Nov 5, 2025
$545.00 for registrations received after this time

Group (5 registrants minimum)
Last day for $445.00 Regular pricing: Nov 5, 2025
$495.00 for registrations received after this time

Group (10 registrants minimum)
Last day for $395.00 Regular pricing: Nov 5, 2025
$445.00 for registrations received after this time

Cancellation Policy
Last day for full refund cancellation: Nov 14, 2025
$50 processing fee applied after this date
Last day for cancellation: Nov 17, 2025

Venue

Clifford Chance, Houston

Texas Tower
845 Texas Avenue
Houston, TX 77002
713-821-2800
Map

Parking Information

If you are walking or taking a rideshare to the conference, we recommend getting dropped off on the corner of Milam St. & Texas Ave. This drop-off spot gives you the quickest and easiest access to the building's lobby from street level.

For those driving to to the conference and need to park in the building, you can enter the right-hand side visitor parking entrance on Travis St. Parking is first come first served on levels 3-12. Please bring your parking ticket to the UT registration desk for validation.

Upon arrival inside the building, all attendees must check in with the security desk on the first floor. Names of registered attendees and speakers have already been added to the security list. After checking in, security will escort you to the elevators for access to the 27th floor.

Our Sponsors

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

Deloitte Tax LLP

Deloitte Tax LLP
www.deloitte.com

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.
Kirkland & Ellis LLP

Kirkland & Ellis LLP
www.kirkland.com

With a global platform of approximately 4.000 lawyers in 22 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.
Liskow & Lewis

Liskow & Lewis
www.liskow.com

Liskow & Lewis was founded in 1935 and includes over 140 lawyers in five offices, located in New Orleans, Lafayette, and Baton Rouge, Louisiana; Houston, Texas; and New York, New York. 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.
Miller & Chevalier Chartered

Miller & Chevalier Chartered
www.millerchevalier.com

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, 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.
Nelson Mullins Riley & Scarborough LLP

Nelson Mullins Riley & Scarborough LLP
www.nelsonmullins.com

Established in 1897, Nelson Mullins is a full-service Am Law 100 firm of more than 1,000 attorneys, policy advisors, and professionals with offices across the United States serving clients in more than 100 practice areas. At Nelson Mullins, our client relationships are based on a deep understanding of our clients’ business worlds and up front communications regarding client objectives. Together, we serve as trusted advisors to clients across a range of business sectors with client relationship fundamentals of quality, dependability, solution-oriented service, and value.
Vinson & Elkins LLP

Vinson & Elkins LLP
www.velaw.com

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
Clifford Chance US LLP

Clifford Chance US LLP
https://www.cliffordchance.com

Oil, Gas, and Energy Taxation Symposium

Overview

Event Schedule

Wednesday Morning, Nov. 19, 2025

Wednesday Afternoon, Nov. 19, 2025

Conference Faculty

Planning Committee

Credit Info

MCLE Credit

Other Credit

Key Dates

Venue

Clifford Chance, Houston

Parking Information

Our Sponsors

Deloitte Tax LLP

Kirkland & Ellis LLP

Liskow & Lewis

Miller & Chevalier Chartered

Nelson Mullins Riley & Scarborough LLP

Vinson & Elkins LLP

Clifford Chance US LLP

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