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eConference

2025 Oil, Gas, and Energy Taxation eConference (audio only)

Contains material from Nov 2025
2025 Oil, Gas, and Energy Taxation eConference (audio only)
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As the oil, gas, and energy taxation landscape evolves, staying ahead isn’t just about keeping up—it’s about gaining insight, strategy, and professional connections.
 
This special symposium—a focused program spun off from the renowned Parker C. Fielder Oil, Gas, and Energy Taxation Conference—brings together top minds in oil, gas, and energy taxation to unpack the latest developments and tackle the most pressing issues facing practitioners and companies today. Topics include:
  • A Look at the State of the Energy Industry
  • Federal Legislative Updates
  • Federal Regulatory Updates
  • Working with the Current IRS: What’s Changed and What Do You Need to Know?
  • Current Practice Issues and Considerations in Oil and Gas Taxation
  • Hot Topics: Renewable Energy Tax Credits after the OBBB Act
  • Trends in Litigation and Controversies

Includes: Audio Transcript Paper Slides

  • Total Credit Hours:
  • 6.50
  • Credit Info
  • TX, CA, OK, PA
  • TX MCLE credit expires: 2/28/2027
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Sessions

Credit
1. Opening Keynote Presentation: Global Outlook and the View to 2050 (Nov 2025)

Rosina Chaker

0.75 0.00 0.00 0.75
Session Materials
Audio (mp3) – 43 mins
Transcript (txt)
Slides (pdf) – 17 pgs

Session 1 —43 mins 0.75

Opening Keynote Presentation: Global Outlook and the View to 2050 (Nov 2025)

Hear ExxonMobil’s view of demand and supply of energy and related products through 2050.

Originally presented: Nov 2025 Oil, Gas, and Energy Taxation Symposium

Rosina Chaker, Industry Outlook Manager, ExxonMobil

2. Federal Legislative Update (Nov 2025)

Layla J. Asali, Mark Dundon, Jessica Blair Theilken

1.00 0.00 0.00 1.00
Session Materials
Audio (mp3) – 63 mins
Transcript (txt)
Slides (pdf) – 15 pgs

Session 2 —63 mins 1.00

Federal Legislative Update (Nov 2025)

Discuss the recently enacted One Big Beautiful Bill Act and the prospects for additional tax legislation this year.

Originally presented: Nov 2025 Oil, Gas, and Energy Taxation Symposium

Layla J. Asali, Miller & Chevalier Chartered - Washington, DC
Mark Dundon, Kirkland & Ellis LLP - Houston, TX
Jessica Blair Theilken, KPMG LLP - Dallas, TX

3. Federal Regulatory Update (Nov 2025)

William Trey Cornelius, Jim Reardon

0.75 0.00 0.00 0.75
Session Materials
Audio (mp3) – 51 mins
Transcript (txt)
Slides (pdf) – 22 pgs

Session 3 —51 mins 0.75

Federal Regulatory Update (Nov 2025)

From the Inflation Reduction Act to the National Environmental Policy Act, discuss the Trump Administration’s rollback of agency regulations and the Supreme Court’s decisions scaling back deference to agency regulations. The President has issued a number of Executive Orders that call for the elimination of obsolete federal regulations, but he has also issued an Executive Order calling for an acceleration of agency guidance under the One Bill Beautiful Bill Act’s tax provisions (“OBBBA”). Outline what federal agencies have done to date to align with the Trump Administration’s agenda. To the extent relevant for energy infrastructure projects and renewable energy tax credits, discuss proposals in Congress to expedite federal agency permitting of large-scale projects, taking into consideration the shortened timeline to qualify for certain renewable energy tax credits under the OBBBA.

Originally presented: Nov 2025 Oil, Gas, and Energy Taxation Symposium

William Trey Cornelius, Deloitte Tax LLP - Houston, TX
Jim Reardon, Nelson Mullins Riley & Scarborough LLP - Houston, TX

4. Working with the Current IRS: What's Changed and What You Need to Know (Nov 2025)

Michael J. Desmond, Bill Wilson

1.00 0.00 0.00 1.00
Session Materials
Audio (mp3) – 57 mins
Transcript (txt)
Paper (pdf) – 15 pgs
Slides (pdf) – 12 pgs

Session 4 —57 mins 1.00

Working with the Current IRS: What's Changed and What You Need to Know (Nov 2025)

As the IRS goes through an historic period of transition and change, the challenges for taxpayers and practitioners in seeking to resolve unsettled tax positions are greater than ever. Turnover in leadership and material declines in staffing at the IRS contribute to compounding delays that are a source of frustration for all. In this environment, it is more important than ever to understand the paths available for taxpayers to obtain certainty in their return reporting positions, ranging from opinions and letter rulings on the front end to administrative appeals and litigation on the back end. This session provides an overview of those procedures and discuss ways in which taxpayers can effectively utilize them in the current resource constrained environment.

Originally presented: Nov 2025 Oil, Gas, and Energy Taxation Symposium

Michael J. Desmond, Miller & Chevalier Chartered - Washington, DC
Bill Wilson, Whitley Penn, LLP - Plano, TX

5. Current Issues and Considerations in Oil and Gas Taxation: New Twists on Established Concepts (Nov 2025)

John T. Bradford, Greg Matlock, Julia Pashin

1.00 0.00 0.00 1.00
Session Materials
Audio (mp3) – 57 mins
Transcript (txt)
Slides (pdf) – 13 pgs

Session 5 —57 mins 1.00

Current Issues and Considerations in Oil and Gas Taxation: New Twists on Established Concepts (Nov 2025)

Examine recent developments in the economic interest concept dealing with the availability of an alternate source of investment recovery. Discuss meeting the requirements for an election out under Section 761 in cases where third-party vendors dispose of hydrocarbon products such as “skim oil” and “drip” condensate on behalf of the producers in a joint operating agreement and where a gas balancing agreement is included in the joint operating agreement. Conclude by addressing certain drafting considerations, including with respect to the “Allocated Values” and Section 1060 allocation schedules to an oil and gas property purchase agreement to optimize the bonus depreciation deduction revitalized by the 2025 One Big Beautiful Bill Act.  

Originally presented: Nov 2025 Oil, Gas, and Energy Taxation Symposium

John T. Bradford, Liskow & Lewis - Houston, TX
Greg Matlock, Ernst & Young, LLP - Houston, TX
Julia Pashin, Akin Gump Strauss Hauer & Feld LLP - Dallas, TX

6. Hot Topics: Renewable Energy Tax Credits after the OBBB Act (Nov 2025)

Todd Lowther, Amish M. Shah, Jenny Speck

1.00 0.00 0.00 1.00
Session Materials
Audio (mp3) – 56 mins
Transcript (txt)
Slides (pdf) – 22 pgs

Session 6 —56 mins 1.00

Hot Topics: Renewable Energy Tax Credits after the OBBB Act (Nov 2025)

Discuss key issues stemming from recent changes to U.S. renewable energy tax credit programs under the OBBB Act, including Executive Orders and sub-regulatory guidance issued after the OBBB Act was signed into law on July 4, 2025 and how companies have been addressing those issues in the months following the enactment of the OBBB Act.

Originally presented: Nov 2025 Oil, Gas, and Energy Taxation Symposium

Todd Lowther, Clifford Chance US LLP - Houston, TX
Amish M. Shah, Holland & Knight LLP - Washington, DC
Jenny Speck, Vinson & Elkins LLP - Houston, TX

7. Trends in Litigation and Controversies (Nov 2025)

George M. Gerachis, Robert C. Morris, Leah Davis Patrick

1.00 0.00 0.00 1.00
Session Materials
Audio (mp3) – 57 mins
Transcript (txt)
Slides (pdf) – 26 pgs

Session 7 —57 mins 1.00

Trends in Litigation and Controversies (Nov 2025)

Address changes in the federal income tax enforcement environment under the Trump Administration. Discuss the state of partnership audits, both from a substantive and procedural perspective, as well as enforcement targeted at Biden-era “green credits.”  In addition, hear the panelists' experiences with the government’s assertion of anti-abuse doctrines and anti-abuse regulations in tax litigation, particularly involving partnership and international issues. 

Originally presented: Nov 2025 Oil, Gas, and Energy Taxation Symposium

George M. Gerachis, Vinson & Elkins LLP - Houston, TX
Robert C. Morris, Norton Rose Fulbright US LLP - Houston, TX
Leah Davis Patrick, Kirkland & Ellis LLP - Houston, TX