Renn G. Neilson

Section Chair - State Tax (Firmwide) Partner


P: +1.713.229.1671 F: +1.713.229.7971
Renn Neilson Photo

Renn Neilson's practice focuses on state and local taxation, incentives and unclaimed property. He helps clients restructure their holdings, acquire and dispose of assets and structure financing transactions to minimize tax exposure. Mr. Neilson regularly defends taxpayers in property, franchise/income and sales tax controversies.

Some recent representative matters include: representing large corporations in major statewide property tax litigation; sales and franchise tax controversy matters; advising clients on unclaimed property issues; representing industrial and energy developers in tax planning and tax incentive negotiations on a nationwide basis; drafting Texas tax legislation; Texas franchise tax restructurings; structuring capital intensive development projects; property valuation and property tax methodology cases; multistate nexus and liability planning; bundled sales and service transactions; intercorporate service transactions; managed audits; numerous state-level taxability inquiries and related negotiations on the state and local tax authorities.

Related Experience

  • Heavy equipment dealer property tax litigation involving over 1,000 lawsuits and a total win at the Texas Supreme Court on Appeal which resulted in a favorable outcome
  • Texas Supreme Court appeal of state franchise tax sourcing issues which resulted in a favorable outcome
  • Sales and use tax litigation in many states which resulted in favorable outcomes
  • State and local tax incentive work, particularly involving large industrial projects and renewable energy development
  • Property tax controversies involving many valuation and exemption issues, including property tax litigation for various power generation companies
  • Representation of major corporate entities in state sales tax controversies involving use of manufacturing exemptions, resales, most other exemptions, and purchasing offices
  • Supervising major unclaimed property audits, controversies and related legislation
  • Representation of major corporate entities in state income and franchise tax controversies
  • Handling state and local tax incentive work; minimizing state and local exposure arising from acquisitions, dispositions, development agreements, construction agreements and equipment acquisitions; state and local tax controversy work for major fossil fuels and alternative energy developers
  • Pursuing state sales and use tax refunds; handling state and local tax structuring issues arising from asset dispositions and acquisitions
  • Managing legislative matters regarding Texas and Louisiana taxation; and state tax controversy matters for a major energy distribution company
  • Handling state tax issues arising in connection with the sale of significant business segments and tax-driven restructurings for major oil field service companies
  • Planning for multistate asset acquisition transactions; planning for asset dispositions and internal restructuring transactions; obtaining federal and state tax rulings in connection with complicated exchange transactions; handling legislative matters regarding Texas taxation for major independent oil and gas producers
  • Handling state and local tax matters arising in connection with asset acquisitions; negotiating and documenting tax increment financing transactions and similar tax incentive work for retail and residential property developers
  • State and local tax issues and incentive work arising from acquisitions, dispositions and structural planning for a multinational manufacturing corporation; dealing with tax issues arising from financing transactions and the construction of manufacturing facilities; negotiating and drafting tax abatement agreements; and handling legislative matters regarding Texas taxation
  • Structuring and documenting exchange transactions to take advantage of the parking arrangements allowed under Rev. Proc. 2000-37 and the built-to-suit rules for major real estate owners and developers

Awards & Community

Listed in Chambers USA, 2016-2017

Recognized as a Texas Super Lawyer-Rising Star (Thomson Reuters), 2004 and a Texas Super Lawyer (Thomson Reuters), 2006-2010, 2013-2018

Listed in The Best Lawyers in America (Woodward & White, Inc.), 2010-2018


Publications, Speeches & Presentations