University of Texas School of Law

eConference

2017 Biennial Parker C. Fielder Oil and Gas Tax eConference (Dec 2017)

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Listen to 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 eConference.

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
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Total Credit Hours:
13.75 | 1.00 ethics     Credit Info
Specialization: Oil, Gas and Mineral Law | Tax Law | Oil, Gas and Mineral Law | Tax Law

TX MCLE credit expires: 12/31/2019

Includes: Audio Paper Slides

$545  

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Credit Hours
1. The Global Energy Challenge and How the U.S. Fits (Dec 2017)

Kenneth B. Medlock III

0.75 0.00 0.00 0.75  

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Audio (mp3) 46 mins
Slides (pdf) 19 pgs

SESSION 1 — 46 mins, credit 0.75

Session 1:

The Global Energy Challenge and How the U.S. Fits (Dec 2017)

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. 

Originally presented at: Nov 2017 Oil and Gas Tax Conference

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

2. Capital Cost Recovery (Dec 2017)

Thomas L. Evans, J. Shayne Buchanan, Scott K. Dinwiddie, John F. Eiman, C. Ellen MacNeil, Bret A. Oliver

1.50 0.00 0.00 1.50  

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Audio (mp3) 92 mins
Slides (pdf) 5 pgs
Slides (pdf) 6 pgs
Slides (pdf) 7 pgs
Slides (pdf) 16 pgs
Slides (pdf) 17 pgs

SESSION 2 — 92 mins, credit 1.50

Session 2:

Capital Cost Recovery (Dec 2017)

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.

Originally presented at: Nov 2017 Oil and Gas Tax Conference

Thomas L. Evans, Kirkland & Ellis LLP - Chicago, IL
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

3. Current Issues in International Tax for the General Practitioner (Dec 2017)

Carol P. Tello, Anne Devereaux, Kevin L. Kenworthy, N. Susan Stone

1.00 0.00 0.00 1.00  

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Audio (mp3) 61 mins
Slides (pdf) 15 pgs

SESSION 3 — 61 mins, credit 1.00

Session 3:

Current Issues in International Tax for the General Practitioner (Dec 2017)

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.

Originally presented at: Nov 2017 Oil and Gas Tax Conference

Carol P. Tello, Eversheds Sutherland - Washington, DC
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

4. Tax Administration: LB&I Commissioner’s Perspective (Dec 2017)

Douglas W. O'Donnell

0.50 0.00 0.00 0.50  

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Audio (mp3) 39 mins

SESSION 4 — 39 mins, credit 0.50

Session 4:

Tax Administration: LB&I Commissioner’s Perspective (Dec 2017)

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.

Originally presented at: Nov 2017 Oil and Gas Tax Conference

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

5. Oil and Gas Investment Vehicles Revisited (Dec 2017)

Denney L. Wright, Maria T. Collman, Robert A. Jacobson, Clifford M. Warren

0.75 0.00 0.00 0.75  

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Audio (mp3) 51 mins
Slides (pdf) 12 pgs

SESSION 5 — 51 mins, credit 0.75

Session 5:

Oil and Gas Investment Vehicles Revisited (Dec 2017)

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.  

Originally presented at: Nov 2017 Oil and Gas Tax Conference

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

6. Partnership Allocation Issues: An Analysis of Functional Allocations, Target Allocations and the New Disguised Sale Regulations (Dec 2017)

John T. Bradford, William H. Caudill, Timothy J. Devetski, Michael L Johnston, Clifford M. Warren

1.25 0.00 0.00 1.25  

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Audio (mp3) 77 mins
Paper (pdf) 10 pgs
Slides (pdf) 25 pgs

SESSION 6 — 77 mins, credit 1.25

Session 6:

Partnership Allocation Issues: An Analysis of Functional Allocations, Target Allocations and the New Disguised Sale Regulations (Dec 2017)

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.

Originally presented at: Nov 2017 Oil and Gas Tax Conference

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

7. International Tax Planning Issues—Evolving in the Face of Uncertainty (Dec 2017)

Heather B. Crowder, Edward C. Osterberg Jr., David Petrick, Moshe Spinowitz, Kenneth Wood

1.25 0.00 0.00 1.25  

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Audio (mp3) 79 mins
Slides (pdf) 9 pgs
Slides (pdf) 21 pgs

SESSION 7 — 79 mins, credit 1.25

Session 7:

International Tax Planning Issues—Evolving in the Face of Uncertainty (Dec 2017)

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. 

Originally presented at: Nov 2017 Oil and Gas Tax Conference

Heather B. Crowder, Phillips 66 - Houston, TX
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

8. Select Tax Issues for Distressed Companies (Dec 2017)

James D. Reardon, Roger D. Aksamit, Glenn Dance, Abdon Rangel, Howard Tucker

1.25 0.00 0.00 1.25  

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Audio (mp3) 74 mins
Slides (pdf) 34 pgs
Slides (pdf) 3 pgs
Slides (pdf) 2 pgs
Slides (pdf) 2 pgs
Slides (pdf) 4 pgs
Slides (pdf) 8 pgs

SESSION 8 — 74 mins, credit 1.25

Session 8:

Select Tax Issues for Distressed Companies (Dec 2017)

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.

Originally presented at: Nov 2017 Oil and Gas Tax Conference

James D. Reardon, Porter Hedges LLP - Houston, TX
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

9. International Compliance  (Dec 2017)

Steven C. Wrappe, John D. Bates, Brandon Bingham, Melinda Harvey

1.25 0.00 0.00 1.25  

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Audio (mp3) 70 mins
Slides (pdf) 15 pgs

SESSION 9 — 70 mins, credit 1.25

Session 9:

International Compliance  (Dec 2017)

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.

Originally presented at: Nov 2017 Oil and Gas Tax Conference

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

10. The New Partnership Audit Rules (Dec 2017)

Elizabeth McGinley, George Hani, Holly O. Paz

1.00 0.00 0.00 1.00  

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Audio (mp3) 58 mins
Slides (pdf) 14 pgs

SESSION 10 — 58 mins, credit 1.00

Session 10:

The New Partnership Audit Rules (Dec 2017)

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. 

Originally presented at: Nov 2017 Oil and Gas Tax Conference

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

11. Avoiding Potential Discipline Situations (Dec 2017)

Linda Galler, Christopher S. Rizek

1.00 1.00 0.00 1.00 | 1.00 ethics  

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Audio (mp3) 58 mins
Slides (pdf) 19 pgs

SESSION 11 — 58 mins, credit 1.00 | 1.00 ethics

Session 11:

Avoiding Potential Discipline Situations (Dec 2017)

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. 

Originally presented at: Nov 2017 Oil and Gas Tax Conference

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

12. Hot Topics in Oil and Gas Tax (Dec 2017)

P. Todd Way, Jennifer Bernardini, Julie M. Holmes Chapel, Glenn Leishner, Allison D. Mantor, Ted McElroy

1.00 0.00 0.00 1.00  

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Audio (mp3) 59 mins
Paper (pdf) 7 pgs
Paper (pdf) 8 pgs
Slides (pdf) 12 pgs
Slides (pdf) 3 pgs
Slides (pdf) 8 pgs

SESSION 12 — 59 mins, credit 1.00

Session 12:

Hot Topics in Oil and Gas Tax (Dec 2017)

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.

Originally presented at: Nov 2017 Oil and Gas Tax Conference

P. Todd Way, Vinson & Elkins LLP - Dallas, TX
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

13. Tax Controversy and Audit: The Impact of the New LB&I Campaign Strategy on the Oil and Gas Sector (Dec 2017)

Richard A. Husseini, Mickey G. Culpepper, Kimberly A. Edwards, Peter A. Lowy, Kathryn F. Patterson

1.25 0.00 0.00 1.25  

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Audio (mp3) 74 mins
Slides (pdf) 17 pgs

SESSION 13 — 74 mins, credit 1.25

Session 13:

Tax Controversy and Audit: The Impact of the New LB&I Campaign Strategy on the Oil and Gas Sector (Dec 2017)

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.

Originally presented at: Nov 2017 Oil and Gas Tax Conference

Richard A. Husseini, Baker Botts L.L.P. - Houston, TX
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