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Oil & Gas Taxation: Fundamentals and Advanced | PBZOGT 18
REGISTER

  • DATE & TIME

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January 25 - 26, 2018 8:30am - 4:30pm

Midland Country Club

16.00

Member: $495 Non Member: $550 Early Member: $470 Early Non Member: $525

Mr. John Tripp

who should attend


Day 1:
Tax professionals involved in oil and gas industry’s upstream operations and tax professionals whose clients own oil and gas mineral interests. The people who will most benefit from this program are tax staff, tax supervisors and managers moving into the oil and gas industry. This course will also serve as a great review for senior level managers and practitioners that have had prior experience in the industry and are seeking to re-enter the field.
Day 2:
Tax professionals involved in oil and gas industry’s upstream operations and tax professionals whose clients own oil and gas mineral interests. All the participants that have taken the Oil and Gas Taxation: Fundamentals CPE Course.

Objective:


Day 1:
Oil and gas taxation is premised on unique concepts and has many detailed and complex calculations. Finding the answers to tax questions in this area can be difficult and time consuming. This seminar will review current developments in oil and gas taxation and the major tax principles applicable to the industry. In addition, the seminar will analyze the oil and gas Market Segment Specialized Program (MSSP) Audit Guide issued by the IRS to identify important audit issues for IRS agents. The analysis of the MSSP will also highlight the IRS’ position on various oil and gas tax questions, cases and revenue rulings. Recently published oil and gas industry Coordinated Issue Papers will also be discussed. Basic issues including The Pool of Capital Doctrine; Separate Property Elections; The Economic Interest Requirements; C&G Capitalization and Amortization; The leasing and subleasing Transactions including the authority for taking 100%; Cost depletion on sublease bonus income; Intangible drilling and development costs; Depreciation issues specific to oil and gas industry.
Day 2:
Provide experienced practitioners with in-depth coverage of complex issues encountered in the acquisition and disposition of oil and gas properties and other tax issues relating to upstream oil and gas operations. Specific issues are The Depletion deduction, cost and percentage including barrel limitations and the 65% of taxable income limitation; Sales and recapture issues; Sharing arrangements, carried interests, farm outs and other conveyance issues; Electing out of Subchapter K; Production payments; Alternative minimum tax issues; Like kind exchanges involving mineral interest; Unitizations; Introductions of partnerships issues.

Key topics:


Day 1:
Working definitions for oil and gas mineral interests and other industry terminology, including the unit of property and an economic interest. Geological and geophysical costs; Proper tax accounting for the leasing transaction, the subleasing transaction, including lease bonus, sublease bonus, delay rental payments; proper tax treatment of IDCs, including what they are, the election to currently expense, and an election to capitalize IDC s under section 59€.
Day 2:
Complex percentage depletion calculations, limitations, and the use of depletion carryovers; Sharing arrangements, carried interests and other “pool of capital” transactions; AMT issues, including the Section 59€ election; exchange of oil and gas properties; gas balancing agreements.

advanced prep


none

Prerequisites


none

Course level


intermediate/advanced