Domestic Tax Issues for Oil & Gas

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.

Includes: Audio Paper Slides