Concentration

Summary

Renn Neilson’s practice focuses on state and local taxation. 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 state and local tax controversies against the overreaching and mistaken efforts of taxing authorities.

Some recent representative matters include: representing major corporations in significant state and local tax controversy matters; advising clients on unclaimed property issues; representing wind and solar 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; conducting negotiations and drafting documentation to take advantage of state and local tax incentives in multiple states; multistate nexus and liability planning in connection with various corporate restructurings; bundled sales and service transactions; intercorporate service transactions; managed audits; numerous state-level taxability inquiries; federal private letter rulings; complex built-to-suit exchange transactions; and aircraft exchanges using various parking techniques.

Representative Engagements

• Supervising major unclaimed property audits
• State and local tax incentive work, particularly involving renewable energy development
• Texas Supreme Court appeal of state franchise tax sourcing issues
• Representation of major corporate entities in state sales tax controversies
• 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
• Successfully 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
• Resolving 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

Publications, Speeches and Presentations

• AWEA’s Windpower Conference, Anaheim, 2011
• Panelist “State and Local Tax Issues Facing Renewable Energy Developers,” South Texas Wind Energy Conference, September 2010
• Panelist “State and Local Tax Issues Facing Renewable Energy Developers,” Renewable Energy World Conference & Expo North America, Austin, February 2010
• Panelist, “State And Local Tax Issues Facing Wind Energy Developers,” AWEA Windpower 2009 Conference and Exhibition, Chicago, May 2009
• Panelist, “New Developments and Interpretations Relating to the 2009 Texas Franchise Law,” Dallas CPA Society, April 2009
• Panelist, Texas Comptroller’s Annual Franchise Tax Meeting
• “Advising Mid-Sized Corporations,” University of Houston Law Center, Houston, October 2005
• Panelist, “Essentials of Section 1031 Exchanges in Texas,” National Business Institute, Dallas, November 2004