University of Texas School of Law

eCourse

Domestic Tax Issues for Oil & Gas (Dec 2015)

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Session 1: 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.
 
Session 2: 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?
 
Session 3: 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.

Total Credit Hours:
3.25     Credit Info

TX MCLE credit expires: 1/31/2019

Includes: Audio Paper Slides

$145  

Preview Sessions
Credit Hours
1. Back to Basics: Oil and Gas Tax Fundamentals (Dec 2015)

Denney L. Wright, David B. Cubeta, Thomas M. Rathgeb, Philip Tiegerman, Bret Wells

1.25 0.00 0.00 1.25  

Preview Session Materials

You may download session materials
for offline use.

Audio (mp3) 70 mins
Slides (pdf) 8 pgs
Slides (pdf) 19 pgs
Slides (pdf) 9 pgs
Slides
Part 1 – 5 pgs
Part 2 – 6 pgs
(pdf)

Preview limited to first 5 slides
of 55
SESSION 1 — 70 mins, credit 1.25

Session 1:

Back to Basics: Oil and Gas Tax Fundamentals (Dec 2015)

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.

Originally presented at: Nov 2015 Oil and Gas Tax Conference

Denney L. Wright, Exxon Mobil Corporation - Houston, TX
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

2. Property and Tax Issues in Fracking (Dec 2015)

Todd Keator, Diane M. Jenkins, Ted McElroy

0.75 0.00 0.00 0.75  

Preview Session Materials

You may download session materials
for offline use.

Audio (mp3) 42 mins
Slides (pdf) 29 pgs

Preview limited to first 5 slides
of 58
SESSION 2 — 42 mins, credit 0.75

Session 2:

Property and Tax Issues in Fracking (Dec 2015)

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?

Originally presented at: Nov 2015 Oil and Gas Tax Conference

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

3. Purchase and Sale Transactions (Dec 2015)

John T. Bradford, Maria T. Collman, Robert A. Jacobson, Clifford M. Warren, Catherine Lueck Zabel

1.25 0.00 0.00 1.25  

Preview Session Materials

You may download session materials
for offline use.

Audio (mp3) 75 mins
Paper (pdf) 67 pgs
Slides (pdf) 29 pgs

SESSION 3 — 75 mins, credit 1.25

Session 3:

Purchase and Sale Transactions (Dec 2015)

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.

Originally presented at: Nov 2015 Oil and Gas Tax Conference

John T. Bradford, Liskow & Lewis - Houston, TX
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