Mr. Bradford practices energy and natural resources taxation and finance at the state, federal, and international levels. His practice involves advising clients on the tax and business consequences of their acquisitions, dispositions, financings, joint ventures, hedging activities, and day-to-day business operations. He has advised clients regarding structuring complex energy and natural resources joint ventures, asset acquisitions and dispositions, and structured financings. He has represented clients before the Internal Revenue Service on audit, administrative appeal, and for private letter ruling requests. He has extensive experience in the energy and natural resources industry, having practiced for more than 18 years as a tax lawyer for Exxon Corporation (now Exxon Mobil Corporation), having worked in energy and natural resource investment banking at JP Morgan Securities, and having most recently advised clients as a principal in KPMG LLP's Washington National Tax practice.
Mr. Bradford is a frequent speaker on energy and natural resource taxation matters, having presented to the American Petroleum Institute Federal Tax Forum, the University of Texas Parker C. Fielder Oil and Gas Tax Conference, the Rocky Mountain Mineral Law Foundation, the American Bar Association Section of Taxation Energy and Environmental Taxes Committee, the Houston Bar Association Tax and Oil and Gas Sections, the South Texas College of Law Energy Symposium, KPMG LLP's Global Energy Conference, and the Liskow & Lewis Energy Seminar. His articles have been published by The Journal of Taxation, the Rocky Mountain Mineral Law Foundation, Oil, Gas & Energy Quarterly, Oil and Gas Financial Journal, and the KPMG Global Energy Institute. Mr. Bradford has been a guest lecturer on oil and gas taxation at Georgetown University School of Law and currently is Adjunct Professor at the University of Illinois College of Law, where he teaches a seminar class on Energy and Natural Resource Transactions.
· Advised a domestic limited liability company owning oil and gas properties on the issuance of preferred membership interests to raise additional equity capital.
· Advised a domestic limited liability company owning oil and gas properties on establishing a domestic well servicing company.
· Advised a foreign oilfield services company on establishing a U.S. subsidiary to conduct business in the Gulf of Mexico. Advised the new U.S. subsidiary on conducting business in the U.S.
· Advised a domestic oilfield services company on the acquisition of certain onshore drilling rigs.
· Advised a domestic oilfield services technology company on establishing an ownership structure for an operating subsidiary in a country in the Far East. Assisted local counsel in establishing the intermediate holding company and the operating subsidiary.
· Advised a domestic subsidiary company on the restructuring of its businesses and the sale of its shares by a foreign parent company.
· Advised a shareholder of a domestic company on the structuring of a purchase of the shares of stock from another shareholder in the execution of a buy-sell arrangement.
· Advised a large domestic publicly-traded company on structuring its acquisition of an interest in a mature oil field and its joint venture to capture and inject carbon dioxide into that field in an enhanced oil recovery project.
· Advised an international oil and gas company on restructuring the ownership of its petroleum licenses to facilitate a private placement with investors to fund an eastern European gas drilling project.
· Advised an international oil and gas company on structuring its Marcellus midstream operations as a partnership for tax purposes.
· Advised a private domestic oil and gas company on structuring its oil and gas property interests in entities to facilitate private placements of indirect interests in the properties with investors.
· Advised a domestic limited liability company owning oil and gas properties on restructuring its private equity debt and limited liability company membership interests from a tax and finance perspective. Advised the company regarding the organization of a new affiliated limited liability company the membership interests in which would be awarded to employees as incentive compensation. Advised the company regarding its recent private placement and new revolving credit facility.
· Advised a multinational company on structuring a joint venture limited liability company to acquire and exploit overseas oil and gas properties.
· Advised a domestic client on the due diligence review and structure for the multi-billion dollar acquisition of domestic oil and gas properties, including the organization of several limited liability companies to hold the properties.
· Advised the domestic affiliate of a foreign energy and natural resources company on the due diligence review and structure for the acquisition of two electric power generation facilities worth more than $800 million, including the organization of separate limited liability companies to hold the facilities.
· Advised a foreign oil and gas company regarding restructuring its ownership of U.S. oil and gas properties, including the organization of a new tax-efficient limited liability holding company structure to hold the properties.
· Advised a domestic limited liability company on its acquisition of Gulf of Mexico oil and gas pipelines.
· Advised several financial institutions regarding the tax consequences of their domestic production payment, net profits interest, and mezzanine finance transactions with oil and gas company clients.
· Advised a domestic oil and gas company regarding a complex financing structure that was the subject of an IRS audit. Advised the company on strategies and positions in IRS Appellate Division review of the structure.
· Advised a domestic oil and gas company regarding IRS examining agent's request for technical advice to overturn a prior favorable ruling obtained for the company. Represented the company before the IRS National Office.
· Advised the domestic affiliate of a foreign power generation company on FIRPTA tax issues arising from acquisition of domestic wind power generation assets from an investment partnership.
Honors & Affiliations:
· State Bar of Texas, American Bar and Houston Bar Associations - Member, ABA Section of Taxation Partnerships Committee
· Houston Energy Finance Group - Member
· Who's Who in Energy in Houston, Houston Business Journal, November 2011
· Panel - Current Issues and Trends in Acquisitions and Dispositions of Oil and Gas Properties, 11th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, October 2011
· Speaker - "What's Next for Oil and Gas Companies in the Federal Tax and Budget Debate?", Liskow & Lewis Energy Law Seminar, October 2011
· Panel - Case Study: Structuring Oil and Gas Deals - Industry Conventions, Economics and Tax Issues, 10th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, October 2009
· Panel - Damn the Torpedoes: Continuing to Finance U.S. Oil and Gas Operations in Tumultuous Times, 55th Annual Rocky Mountain Mineral Law Institute, July 2009
· Panel - Enhanced Oil Recovery and Carbon Sequestration: Sections 193 and 45Q and Beyond, 75th Annual American Petroleum Institute Federal Tax Forum, April 2009
· Panel - Economic Planning for Projects and the Role of the Tax Department, 74th Annual American Petroleum Institute Federal Tax Forum, April 2008
· Tax Planning for Joint Operations: Keeping the After-Tax Economics of the Trade Intact, Rocky Mountain Mineral Law Foundation Special Institute on Oil and Gas Agreements: Joint Operations, March 2008, December 2007, and May 2007, Houston Bar Association Oil and Gas Section 2007
· Upstream Federal Tax Issues, South Texas College of Law 20th Annual Energy Law Institute, November 2007
· Panel - Fundamentals of Oil and Gas Trading/Hedging Transactions, American Bar Association Section of Taxation May Meeting, May 2006
· Panel - Energy Trading and Hedging, 8th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, October 2005
· Panel - Financing Oil and Gas Operations: Domestic and International Issues, 7th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, October 2003
· "IRS Office of Chief Counsel Issues Guidance on the IDC Tax Preference for AMT Purposes," Liskow & Lewis E-Newsletter, September 12, 2012
· "Income Tax Returns for Oil and Gas Producers: Computing the IDC Preference in the Alternative Minimum Tax," Liskow & Lewis E-Newsletter, April 2010
· Tax Efficient "Cash and Carry" Transactions: A Retail Concept Finds Its Way Into the Oil Patch, Oil and Gas Financial Journal, February 2010
· Damn the Torpedoes: Continuing to Finance U.S. Oil and Gas Operations in Tumultuous Times, 55th Annual Rocky Mountain Mineral Law Foundation Institute, 2009 (with J. Mosley)
· Oil and Gas Mezzanine Finance Transactions: Don't Get Tripped Up by the Equity Kicker, Oil, Gas & Energy Quarterly (vol. 57, no. 3 March 2009) (with P. Kunkel)
· The AMT Depletion Preference and the Tax Court: The Decline of Mineral Tax Erudition, The Journal of Taxation (vol.109, no. 6 Dec. 2008) (with R. Swiech)
· Tax Planning for Joint Operations: Keeping the After-Tax Economics of the Trade Intact, Rocky Mountain Mineral Law Foundation Journal (vol. 45, no. 1 2008), Oil, Gas & Energy Quarterly (vol. 56, no. 3 March 2008)
· Production payments in international oil and gas operations: using a US financing tool overseas, International Tax Review, Energy Supplement, September 2004 (with M. Holtman)
· Volumetric production payments in property transactions: tax rules and potential benefits, Oil and Gas Financial Journal, September 2004 (with M. Holtman)