transcript   Transcript

Oil and Gas Industry

Recorded on: Jun. 7, 2018
Running Time: 00:59:25

Full Transcript:



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To access the streaming media of this presentation, please purchase the corresponding seminar segment.

CPE credit (NASBA QAS Self-Study) is available by completing and passing the program’s CPE Review & Exam.

Taken from the Web Program Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances  Recorded June, 2018 in San Francisco [00:59:25]

An introduction to the rules and concepts governing oil and gas transactions, including Section 613(A)(c)(7)(D); treatment as a partnership versus other arrangements; election out of subchapter K under Section 761; use of tax partnerships to solve oil and gas tax issues in contractual joint ventures
Kevin M. Richards

Upon the successful completion of this program, the participant will be able to:

  • Recall the tax treatment of oil and gas industry sharing arrangements and carry agreements.
  • Recognize the tax treatment of oil and gas industry tax partnerships.
  • Describe the impact of capital account maintenance on the taxation of oil and gas industry tax partnerships.

Course Overview:

This program will focus on:

  • The tax treatment of oil and gas industry sharing arrangements and carry agreements.
    • Sharing arrangements.
      • Fundamentals of oil and gas taxation.
      • Pool of Capital (POC) Doctrine.
    • Carried interests.
      • Complete payouts.
      • Fractional interest rule.
      • Revenue Ruling 77-176.
      • Multi-property farmout.
      • Reimbursement of leasehold acquisition costs.
      • Unused carry.
  • The tax treatment of oil and gas industry tax partnerships.
    • Internal Revenue Code (IRC) §761(a) elections.
    • Avoiding the fractional interest rule.
    • Avoiding Revenue Ruling 77-176.
    • Reimbursement of leasehold acquisition costs.
    • Unused carry.
  • The impact of capital account maintenance on the taxation of oil and gas industry tax partnerships.
    • Initial capital accounts.

CPE Program Level:  Update

Intended Audience:  CPA’s, tax accountants, tax lawyers, taxpayers, compliance professionals, and others seeking an introduction to the tax rules and concepts governing oil and gas transactions.  

Prerequisites:  A basic knowledge of the tax rules and concepts governing oil and gas transactions.

Advanced Preparation:  None

Instructional Method:  QAS Self-Study

Updated:  December 2018

Credit Information:  1 CPE credit is available upon completion of this program’s 3 content-review questions and a minimum passing score of 70% on the 5-question final exam.

The purchase price of this Web Program segment includes the following article from the Course Handbook available online:

  • Joint Committee on Taxation: Description of Present Law and Select Proposals Relating to the Oil and Gas Industry (JCX-27-11, May 11, 2011)
  • Everyone Out of the Pool! (and into the Tax Partnership) (PowerPoint slides)
    Kevin M. Richards, Gary R. Huffman
Presentation Material
  • Everyone Out of the Pool! (and into the Tax Partnership)
    Kevin Richards
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