Spring 2024
Professor(s):
Denney Wright (OTHER FACULTY)
Credits: 3
Course Areas: Taxation
Energy, Natural Resources and Environmental Law
Time: 1:00p-2:30p MW Location: 221
Course Outline: Oil and Gas Income Taxation covers the United States federal income taxation of domestic oil and gas operations and transactions. The course examines taxation associated with the operational life cycle of oil and gas operations including exploration, development, production and abandonment. The study of transactions involving oil and gas interests analyzes acquisition, disposition, structuring and investment. Course participants learn the historical context and development of oil and gas provisions found in the U.S. tax law. Current tax legislative proposals or enactments that affect the oil and gas industry are addressed if warranted. The emphasis is on federal income taxation of domestic oil and gas transactions, although certain international tax aspects of the oil and gas business will be referenced and contrasted throughout the class.
Course Syllabus: Syllabus
Course Notes: (Face-to-Face) The UH registration system instruction mode for this course is listed in parenthesis. For this instruction mode, instructors and students are expected to normally be physically present in the classroom. If the course has a final examination, it will be in a classroom requiring your physical presence. Other assessment, such as a mid-term exam, may also be in a classroom. Whether this instructor will offer “remote presence” (starting a zoom meeting from the podium computer to enable student remote access on an occasional basis) for part or all of the semester is not known, but students should not rely on an expectation that remote presence will be available.
This is an LL.M class, and JD students may register, if space is available.
Prerequisites: Federal Income Tax & Oil and Gas Law are recommended
First Day Assignments: Introduction to oil and gas operations and associated tax issues including discussion of industry, life cycle of an oil and gas investment and discussion of federal v. state/local law in
federal income tax
Casebook: pp. 1-48
Supplemental as needed: pp. 1-23
Final Exam Schedule: 5/1/2024 1-4 221
This course will have:
Exam:
Paper:
Satisfies Senior Upper Level Writing Requirement: No
Experiential Course Type: No
Bar Course: No
DistanceEd ABA: No
Pass-Fail Student Election: Available
Course Materials
Book(s) Required
Course Materials: Denney L. Wright, Oil and Gas Tax: A Comprehensive Study, Aspen Select Series/Aspen Publishers, 2019 Ed. (ISBN 9781543816112)
Other Text Resources (supplements to required text for optional/additional reference)
Wolters Kluwer Editorial Staff, Oil and Gas: Federal Income Taxation, Wolters Kluwer, 2022 Ed. (ISBN 978-0-8080-5661-4)
Robert Polevoi and William H. Byrnes, IV, Federal Taxation of Oil and Gas Transactions, Matthew Bender, (ISBN 978-0820512808) (available in O'Quinn Law Library UHLC)
