Oil and Gas Taxation: Advanced and Update (OILADV)
Minot Grand International
8 CPE Hours
$250 Member ($300 Nonmember)
Add $25 after 8/10/2010
Instructor: John C. Tripp, Ph.D., CPA
This program will provide experienced practitioners with in-depth coverage of complex issues encountered in the acquisition, operation and disposition of oil and gas properties. It will also bring practitioners up to date by focusing on current developments relating to the major tax principles applicable to upstream operations. The materials for this program include a complete copy of the IRS MSSP on the Oil and Gas Industry. The author’s outlines are cross referenced to the MSSP as well as CCH’s recently published treatise Oil and Gas - Federal Income Taxation (2010 Edition). These reference materials are used to highlight the IRS’s 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.
Objectives:
To determine the proper cost depletion and percentage depletion for each unit of property: including barrel limitations, taxable income from the property limitations, and the 65% of the taxpayer's taxable income limitation and the use of depletion carryovers.
To understand the proper tax treatment of sharing arrangements and carried interests
To determine the proper tax consequences upon the sale or abandonment of an oil and gas mineral interest
To understand the AMT issues relating to the IDC tax preference item and the election to capitalize IDCs under section 59(e) to help ameliorate the AMT burden
To properly apply the like kind exchange rules regarding exchanges of oil and gas properties, including the Section 1254 recapture provisions.
Major Topics:
Complex percentage depletion calculations, limitations, and the use of depletion carryovers
Sales of oil and gas properties with an emphasis on current deal structures
Sharing arrangements, carried interests and other “pool of capital” transactions
AMT issues, including the Section 59(e) election
Like kind exchanges of oil and gas properties
Electing out of subchapter K and gas balancing agreements
Designed For: Tax professionals involved in the oil and gas industry's upstream operations and tax professionals whose clients own oil and gas mineral interests. Also, all the participants that have taken the Oil and Gas Taxation: Fundamentals CPE Course.
Level: Advanced Developer: John Tripp Prerequisite: Oil and Gas Taxation: Fundamentals
