Curriculum Guide · Courses

Professors Stephen Comstock and John Gimigliano

LL.M Seminar 945 (cross-listed) | 2 credit hours

Many experts believe that energy markets will be to the current decade what the internet and high technology markets were to the 1990s. Rapid evolution of energy technologies and massive capital investments in energy have also meant a period of dynamic change for the Tax Code. For many years, Congress has used the tax laws to encourage industry to identify new sources of energy and to investigate alternative technologies. The Energy Policy Act of 2005 represented the largest congressional investment in alternative energy ever. Still, this may pale in comparison with what Congress could enact in response to the challenge of global warming.

This course will examine three important areas of energy tax policy: (1) taxation of the oil and gas industry (including long-standing fossil fuel incentives and tax rules unique to exploration, production and refining of oil and natural gas); (2) taxation of electric utility and natural gas markets (including tax changes flowing from deregulation of these markets and tax proposals to address climate change); and (3) tax subsidies and tax incentives for alternative energy development (including analysis of creative tax-planning structures designed to maximize the value of these incentives).

The course is designed to help students appreciate the challenges confronted by tax practitioners in this rapidly changing environment. Some sessions will feature guest lecturers. There will be a final examination at the end of the semester.

Prerequisite: Tax I. Recommended: Corporate Tax Law I or Taxation II.