SALT

Energy

The SALT team represents some of the largest multinational integrated energy companies who are engaged in the exploration and production of hydrocarbons and minerals, marine and pipeline transportation and downstream activities including refining and petrochemical operations. Issues we address for energy companies include:

  • Challenges to their global corporate structure in the form of characterizing the income earned by foreign affiliates in certain foreign locations as tax haven income subject to state corporate income tax
  • Challenges to deductions taken for payments made to foreign government entities  for the privilege of doing business and extracting resources in foreign jurisdictions
  • Assuring transportation functions, including marine and pipeline, address  complex apportionment rules and the challenges with sourcing income earned from providing transportation services which often include gathering, storage and processing services
  • Addressing the increased pressure that the downstream refining and retail operations are facing from the imposition of local taxes and registration requirements resulting from the changes in retail business models

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