Course

Description

All materials will be electronic only

This program addresses tax issues arising in the acquisition, operation and disposition of oil and gas interests. It also discusses current developments in the taxation of upstream oil & gas operations.

Highlights

• Acquisition of interests in oil and gas properties
• Percentage depletion calculations, limitations, and the use of depletion carryovers
• Transfers of oil & gas properties
• Sharing arrangements, carried interests and other “pool of capital” transactions
• AMT computations, and § 59(e) elections
• Recapture of natural resources recapture expenses under § 1254
• Like kind exchanges of oil and gas properties
• Electing out of subchapter K and gas balancing agreements

Objectives

• Identification of the types of interests in oil and gas
• Identification of the unit of property for purposes of depletion
• Identification and treatment of geological & geophysical expenditures and intangible drilling and development costs
• Computation of cost depletion and percentage depletion for each unit of property
• Determination of the treatment of sharing arrangements and carried interests
• Computation of gain or loss on the sale or abandonment of an oil and gas mineral interest, including characterization 
• Identification of AMT issues relating to the IDC tax preference item and the election to capitalize IDCs under § 59(e) to help ameliorate the AMT burden
• Application of § 1256 recapture on dispositions of oil and gas interests, including like kind exchanges 

Designed For

Anyone working in Oil & Gas