Overview
Several McDermott attorneys will be speaking at the TEI: 2025 Tax School Week 1 on February 10-13, 2025, in Houston, TX. Register today and join us for the following sessions:
Energy Tax Planning including New Energy and IRA Credits
Speakers: Heather Cooper and Chris Gladbach
Wednesday, February 12
This full-day session will address a variety of tax planning issues and opportunities faced by taxpayers in the energy industry. Session will include updates of IRA energy tax credits. In addition, topics will appeal to domestic and international taxpayers engaged in the upstream, downstream oil and gas and alternative energy businesses. Discussion topics will include:
- U.S. federal income tax energy provisions;
- Tax planning challenges unique to the energy industry;
- Energy specific credits; and
- Energy industry specific controversy.
Partnership Tax Compliance and Planning
Speaker: David Sherwood
Thursday, February 13
This full-day session will cover familiar partnership taxation sub-topics (Tax Credits, special allocations, cross-border structuring, etc.). Speakers are being asked to spend less time on the basic partnership rules and instead focus on recent developments and comprehensive planning strategies. Discussion topics will include:
- Use of partnerships in M&A transactions;
- Impact of Pillar 2 on partnership planning and structuring;
- Partner compensation;
- Proposed legislation/regulations (such as Pillar 2);
- Interplay of tax allocations and the economics of partnership agreements; and
- Partnership audit considerations (BBA rules).
IRS/Tax Controversy
Speakers: Shawn O’Brien and Susan Ryba
Thursday, February 13
As tax authorities continue their quest for transparency and real-time audits and governments around the globe focus on taxation, tax dispute resolution alternatives similarly continue to evolve. This full-day session will provide a view from the front lines as to IRS audits, IRS Appeals, use of APAs/MAPs for cross-border resolution, and tax litigation. Further, we will explore how the US Supreme Court’s decision in Loper Bright and its impact on deference to the IRS in interpreting Treasury Regulations may provide further opportunities in US tax controversies. We also will have a hot topic issue focus on research credit audits and practical strategies for managing them. Discussion topics will include:
- Developments in how the IRS is handling audits;
- How APAs and MAP may be more relevant in handling your cross-border controversies;
- Treasury regulation challenges post-Loper Bright;
- Practical strategies for managing YS research credit audits;
- Developments in IRS Independent Office of Appeals; and
- Recent tax litigation.
