Barbara De Marigny

Partner

Barbara De Marigny

Houston

P: +1.713.229.1258
F: +1.713.229.7958

Carbon Capture/Section 45Q

  • Tax advice regarding availability of Code Section 45Q tax credits to petrochemical plant utilization of ammonia production emission of carbon dioxide
  • Tax advice regarding availability of Code Section 45Q tax credit to ammonia producer
  • Tax advisor to tax equity investor in facility using captured carbon dioxide in enhanced oil recovery operations
  • Tax advice to pore space owner in lease negotiations for Code Section 45Q carbon oxide sequestration
  • Tax advice to oilfield services provider regarding availability of Code Section 45Q tax credit for certain activities
  • Tax advice to oil & gas producer as to secure geologic storage under Code Section 45Q for Class II non-EOR wells
  • Tax advice to oilfield services provider regarding potential joint venture with emitter to obtain Code Section 45Q tax credits
  • Tax advice to exploration and production company regarding section 45Q credit opportunities in connection with production

Partnership and Joint Ventures

  • Advise tax equity investors in renewables partnerships, including tax structuring of PTCs, ITCs and flip structures.
  • Tax advice on $100 m. LLC joint venture formation for oilfield services, saltwater transmission and disposal business.
  • Tax advice to MLP Special Committee on $1.5 b. distribution of MLP pipeline assets in reverse drop-down.
  • Tax advice to one of the largest private timberland owners in the United States on the formation of a processing joint venture.
  • Tax advice to a Fortune 50 telecommunications company on the formation of an international consumer finance joint venture.
  • Tax advice on MLP structures for PE portfolio companies.
  • Tax structuring for acquisitions and drop-downs by MLPs.
  • Advice on qualifying income determinations and negotiation of private letter rulings for MLPs.
  • Tax-free mergers and divisions of partnerships, LLCs and MLPs.
  • Advice on MLP Yieldco and Up-C structures.
  • Advise publicly traded foreign corporations in joint ventures with MLPs.
  • Advise foreign fund investors in domestic renewables partnerships.

Other Tax Experience

  • Tax advice regarding satisfaction of beginning of construction safe harbor to LNG facility
  • Tax advice to PE funds on portfolio company transactions (buy-side and sell-side, both asset and equity interests).
  • Tax structuring for PE funds acquiring oil field service and E&P companies.
  • Tax structuring for legal entity reduction (LER) projects of multinational and domestic corporations.
  • Provision of tax advice to an equity sponsor in the $3 billion stock sale of an offshore drilling company.
  • Provision of tax advice to a Fortune 50 parent in complex restructuring of $25 billion, 150-member corporate group into limited liability company joint venture.
  • Tax advice to an equity sponsor in the $100 million stock sale of an oil field services company.
  • Tax advice to a buyer in $60 million acquisition of limited liability company interests in refining company.
  • Tax advice to an equity sponsor in $80 million sale limited liability company interests in heavy industry.
  • Tax advice to an oil & gas group in $200 million FIRPTA restructure and IPO on London AIM.
  • Tax advice to a Fortune 50 corporation in $300 million Section 1031 build-to-suit exchange transaction.
  • Tax advice on the formation of an offshore oil field service company to defer U.S. tax.
  • Representation of a Fortune 50 company at IRS Appeals on tax consequences of partnership restructuring.
  • Provide tax opinions to New Markets Tax Credit (NMTC) investors.
  • Granted first IRS private letter ruling on tax-free nature of Texas Enterprise Fund grants.
  • Acted as expert witness on flow-through tax structures in federal whistleblower case.