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Domestic Tax Issues for Oil and Gas: Partnership Audit Rules, 1031 Updates, and the Section 45Q Credit

Contains material from Jan 2020

Domestic Tax Issues for Oil and Gas: Partnership Audit Rules, 1031 Updates, and the Section 45Q Credit
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Not enough focus on oil and gas issues. Some good points and information but not tailored sufficiently.

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Session 1: The Evolving Partnership Audit Rules The new centralized partnership audit rules are now in effect and the initial returns subject to those rules have been or will soon be filed. Many of the rules governing the new regime have been finalized but others are still forthcoming. Taxpayers, practitioners and the IRS will learn more about the new regime once audits of those returns commence with regularity. Listen to a discussion about the most recent developments in the evolution of these audit rules.
 
Session 2: 1031 Update for Oil & Gas Significant changes have occurred in the 1031 world over the prior two years. Learn about the meaning of “real property” as applicable to oil & gas exchanges, the use of Bartell structures for reverse exchanges, issues specific to royalty trusts and tax partnerships, and a comparison to opportunity zone investments as an alternative.
 
Session 3: The New Section 45Q Carbon Capture and Sequestration Credit Listen to a discussion about the section 45Q carbon capture and sequestration credit and the significant changes made to that credit in the Bipartisan Budget Act of 2018 to expand the scope and the amount of the credit. Hear about some of the important considerations in credit qualification related to enhanced oil recovery, secure geological storage, other commercial uses of carbon, transfers of credits, and what guidance is needed for taxpayers in the oil and gas industry to utilize or transact with this credit.

Includes: Audio Slides

  • Total Credit Hours:
  • 2.50
  • Credit Info
  • TX, CA
  • Specialization: Oil, Gas and Mineral Law | Tax Law
  • TX MCLE credit expires: 1/31/2022

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Preview Sessions
Credit

1. The Evolving Partnership Audit Rules (Jan 2020)

Elizabeth McGinley, William Paul Bowers, George Hani, Holly O. Paz

1.00 0.00 0.00 1.00
Preview Materials

Download session materials for offline use

(mp3)
58 mins
Slides
(pdf)
6 pgs
Session 1 —58 mins
1.00
The Evolving Partnership Audit Rules (Jan 2020)

The new centralized partnership audit rules are now in effect and the initial returns subject to those rules have been or will soon be filed. Many of the rules governing the new regime have been finalized but others are still forthcoming. Taxpayers, practitioners and the IRS will learn more about the new regime once audits of those returns commence with regularity. Discuss the most recent developments in the evolution of these audit rules.

Originally presented at: Nov 2019 Oil and Gas Tax Conference

Elizabeth McGinley, Bracewell LLP - New York, NY
William Paul Bowers, Norton Rose Fulbright - Dallas, TX
George Hani, Miller & Chevalier Chartered - Washington, DC
Holly O. Paz, Internal Revenue Service - Washington, DC

2. 1031 Update for Oil & Gas (Jan 2020)

Todd Keator, Robert A. Jacobson, Stephen J. Toomey

0.75 0.00 0.00 0.75
Preview Materials

Download session materials for offline use

(mp3)
45 mins
(pdf)
21 pgs
Session 2 —45 mins
0.75
1031 Update for Oil & Gas (Jan 2020)

Significant changes have occurred in the 1031 world over the prior two years. Discuss and explore the meaning of “real property” as applicable to oil & gas exchanges, the use of Bartell structures for reverse exchanges, issues specific to royalty trusts and tax partnerships, and a comparison to opportunity zone investments as an alternative.   

Originally presented at: Nov 2019 Oil and Gas Tax Conference

Todd Keator, Thompson & Knight LLP - Dallas, TX
Robert A. Jacobson, Willkie Farr & Gallagher LLP - Houston, TX
Stephen J. Toomey, Internal Revenue Service - Washington, DC

3. The New Section 45Q Carbon Capture and Sequestration Credit
  (Jan 2020)

Brian Americus, Robert McCann, Amish M. Shah, Aaron D. Vera

0.75 0.00 0.00 0.75
Preview Materials

Download session materials for offline use

(mp3)
48 mins
(pdf)
17 pgs
Session 3 —48 mins
0.75
The New Section 45Q Carbon Capture and Sequestration Credit
  (Jan 2020)

Discuss the section 45Q carbon capture and sequestration credit and the significant changes made to that credit in the Bipartisan Budget Act of 2018 to expand the scope and the amount of the credit. Hear about some of the important considerations in credit qualification related to enhanced oil recovery, secure geological storage, other commercial uses of carbon, transfers of credits, and what guidance is needed for taxpayers in the oil and gas industry to utilize or transact with this credit.

Originally presented at: Nov 2019 Oil and Gas Tax Conference

Brian Americus, Deloitte - Washington, DC
Robert McCann, Internal Revenue Service - Houston, TX
Amish M. Shah, Eversheds Sutherland (US) LLP - Washington, DC
Aaron D. Vera, Exxon Mobil Corporation - Spring, TX

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