Oil and Gas Tax

Book excerpt: Taxation of oil and gas is one of the more complicated areas of the U.S. federal income tax law. Unique principleshave developed over the years as Congress, the IRS, the courts and taxpayers have designed, interpreted, and pursued energy development. Taxpayers and the government have had to deal with the high risk and significant costs associated with oil and gas development, all within the context of oil and gas production being a core national security priority through the years. The unconventional revolution combined with continued significant conventional development has caused a renewed interest in these matters. Taxation is always crucial in judging the economics of oil and gasdevelopment, so this casebook should prove timely as taxpayers and financial advisors renew their interest — or immerse themselves for the first time — in these concepts and principles. A particular challenge is application of conventional rulesto unconventional production processes, which is highlighted and explored in this timely casebook. The aim of Chapter 1 is to provide an overview of the history of oil and gas development in the United States, as well as to introduce basic federal income tax concepts. This knowledge will facilitate the in-depth study of U.S federal oil and gas taxation in Chapters 2–11. Professors and students will benefit from: Discussion of historic oil and gas industry and general federal income tax issues Discussion of oil and gas tax principles, provisions and policies, highlighting unique aspects of the law Text that fits unconventional development into the conventional tax rules developed over the years Practitioners will benefit from: Refresh of oil and gas tax issues contained in a casebook dedicated entirely to oil and gas tax matters Comparison and contrast of unconventional and conventional principles, policies and tax rules