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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
This work covers the substantive law of oil and gas and federal income taxation of oil and gas transactions. The first three chapters examine interests and transactions in the mineral estate. The fourth chapter covers surface and subsurface issues. Chapters five through eight examine in detail the oil and gas lease. Chapter nine addresses the issue of transfers by the lessor and the lessee. Chapters 10 through 12 are devoted to oil and gas taxation. Students will see that this work gives them quick access to the law of oil and gas and the law of oil and gas taxation.
Oil, gas and mineral deposits are a substantial part of the wealth of many countries, not least in developing and emerging market economies. Harnessing some part of that wealth for fiscal purposes is critical for economic development: in few areas of economic life are the returns to good policy so large, or mistakes so costly.
Mexico has large extractive industries and it traditionally has raised sizable fiscal revenues from the oil and gas sector. A confluence of factors—elevated commodity prices, financial challenges of the state-owned oil company Pemex, and revenue needs for financing social and public investment spending over the medium term—suggest that a review of Mexico’s taxation regimes for natural resources would be opportune, against the backdrop of a comprehensive approach to tackling Mexico’s challenges. This paper identifies opportunities for redesigning mining taxation to increase somewhat the revenue intake while maintaining the favorable investment profile of the sector. It also discusses recent reforms to the oil and gas fiscal regime and future reform considerations, with attention to the attractiveness of investment on commercial terms—an issue that should be placed in the context of an overall reform of Pemex’s business strategy and possibly of the energy sector more generally.
Why should you buy Tolley's International Taxation of Upstream Oil and Gas Third editionThis title sets out the significant international tax issues for upstream oil and gas operations, and with an emphasis on tax risk management and related tax planning. Readers will develop skills in identifying tax exposures and opportunities, managing tax negotiations, and applying tax planning solutions.The book is intended to benefit accountants, lawyers, economists, financial managers and government officials, and is the first choice for new starters in upstream oil and gas taxation.The book serves as a great introduction to international tax issues relating to upstream oil and gas, enabling the reader to analyse and understand new situations and circumstances.This third edition explains recent key developments, including the changes in United States upstream oil and gas taxation, the implementation of the OECD Base Erosion and Profit Shifting (BEPS) measures, and the application of the 2017 OECD Transfer Pricing Guidelines, together with related practical case study examples.
Although host governments and investors may share one common objective - the desire for projects to generate high levels off revenue - their other goals are not entirely aligned. Host governments aim to maximize rent for their country over time, while achieving other development and socioeconomic objectives. Investors aim to ensure that the return on investment is consistent with the risk associated with the project, and with their corporations' strategic objectives. To reconcile these often conflicting objectives, more and more countries rely on transparent institutional arrangements and flexible, nuetral fiscal regimes. This paper examines the key elements of the legal and fiscal frameworks utilized in the petroleum sector and aims to outline desirable features that should be considered in the design of fiscal policy with the objective of optimizing the host government's benefits, taking into account the effect this would have on the private sector's investment.
The domestic taxation of petroleum products is an important source of revenue in most countries. However, there is a wide variation of tax rates on petroleum products across countries, which cannot be explained by economic theory alone. This paper surveys different considerations advanced for taxing petroleum and presents petroleum tax rate data in 120 countries. It concludes that a significant reduction in the present extremely wide variation in petroleum prices and tax rates appears warranted.
Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación
The taxation of natural resources is one of the more complicated areas of the U.S. federal income tax system. From the acquisition of the mineral rights, to the exploration and development of the property, to the ultimate production of the mineral, there are unusual and challenging tax aspects along every step of the way.