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Oil tax

Seismic studies bought along with proven oil and gas properties aren’t amortizable

Seismic studies bought along with proven oil and gas properties aren’t amortizable

Chief Counsel Advice 201552024 In Chief Counsel Advice (CCA), IRS concluded that the costs of seismic data acquired as part of an asset acquisition weren’t geological and geophysical (G&G) exploration costs eligible for amortization under Code Sec. 167(h). The seller used the seismic data to locate and identify productive oil and gas properties, which it […]

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Temp regs cover allocation of Sec. 199 wages in short tax year and in acquisition or disposition

Temp regs cover allocation of Sec. 199 wages in short tax year and in acquisition or disposition

T.D. 9731, 08/26/2015, Reg. § 1.199-2, Reg. § 1.199-2T, Reg. § 1.199-8, Reg. § 1.199-8T IRS has issued temporary regs that provide guidance for purposes of the Code Sec. 199 domestic production activities deduction (DPAD) on the allocation of W-2 wages paid by two or more taxpayers that are employers of the same employees during […]

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IRS Establishes Program That Reallocates Gasification Project Credits

IRS Establishes Program That Reallocates Gasification Project Credits

Notice 2014-81, 2014-52 IRB In a Notice, IRS has established a third phase of the qualifying gasification project program under Code Sec. 48B (“the § Code Sec. 48B Phase III program”) to reallocate the qualifying gasification project credits that are available for allocation after the conclusion of the Code Sec. 48B Phase I program. Background. One […]

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Appellate court affirms that bonus payment under oil and gas agreement was ordinary income

Appellate court affirms that bonus payment under oil and gas agreement was ordinary income

Michael H. Dudek, (CA 3 12/24/2014) 114 AFTR 2d ¶ 2014-5561   The Court of Appeals for the Third Circuit, affirming the Tax Court, has held that an over $800,000 bonus payment taxpayers received under an oil and gas agreement was taxable as ordinary income and not as capital gain as they had reported. This […]

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Christmas surprise: Oil companies oppose an oil tax — with falsehoods

Christmas surprise: Oil companies oppose an oil tax — with falsehoods

Christmas surprise: Oil companies oppose an oil tax — with falsehoods, as reported in the LA Times. The oil industry believes that a state oil severance tax in California would be “bad tax policy” and threaten the state’s economy. It thinks my arguments in favor of the tax, which were laid out a couple of […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney