Taxation of oil and gas is one of the more complicated areas of the U.S. federal income tax law. Unique principleshave developed over the years as Congress, the IRS, the courts and taxpayers have designed, interpreted, and pursued energy development. Taxpayers and the government have had to deal with the high risk and significant costs associated with oil and gas development, all within the context of oil and gas production being a core national security priority through the years. The unconventional revolution combined with continued significant conventional development has caused a renewed interest in these matters. Taxation is always crucial in judging the economics of oil and gasdevelopment, so this casebook should prove timely as taxpayers and financial advisors renew their interest — or immerse themselves for the first time — in these concepts and principles. A particular challenge is application of conventional rulesto unconventional production processes, which is highlighted and explored in this timely casebook. The aim of Chapter 1 is to provide an overview of the history of oil and gas development in the United States, as well as to introduce basic federal income tax concepts. This knowledge will facilitate the in-depth study of U.S federal oil and gas taxation in Chapters 2–11. Professors and students will benefit from: Discussion of historic oil and gas industry and general federal income tax issues Discussion of oil and gas tax principles, provisions and policies, highlighting unique aspects of the law Text that fits unconventional development into the conventional tax rules developed over the years Practitioners will benefit from: Refresh of oil and gas tax issues contained in a casebook dedicated entirely to oil and gas tax matters Comparison and contrast of unconventional and conventional principles, policies and tax rules

Taxation of oil and gas is one of the more complicated areas of the U.S. federal income tax law. Unique principleshave developed over the years as Congress, the IRS, the courts and taxpayers have designed, interpreted, and pursued energy development. Taxpayers and the government have had to deal with the high risk and significant costs associated with oil and gas development, all within the context of oil and gas production being a core national security priority through the years. The unconventional revolution combined with continued significant conventional development has caused a renewed interest in these matters. Taxation is always crucial in judging the economics of oil and gasdevelopment, so this casebook should prove timely as taxpayers and financial advisors renew their interest — or immerse themselves for the first time — in these concepts and principles. A particular challenge is application of conventional rulesto unconventional production processes, which is highlighted and explored in this timely casebook. The aim of Chapter 1 is to provide an overview of the history of oil and gas development in the United States, as well as to introduce basic federal income tax concepts. This knowledge will facilitate the in-depth study of U.S federal oil and gas taxation in Chapters 2–11. Professors and students will benefit from: Discussion of historic oil and gas industry and general federal income tax issues Discussion of oil and gas tax principles, provisions and policies, highlighting unique aspects of the law Text that fits unconventional development into the conventional tax rules developed over the years Practitioners will benefit from: Refresh of oil and gas tax issues contained in a casebook dedicated entirely to oil and gas tax matters Comparison and contrast of unconventional and conventional principles, policies and tax rules

Oil, gas and mineral deposits are a substantial part of the wealth of many countries, not least in developing and emerging market economies. Harnessing some part of that wealth for fiscal purposes is critical for economic development: in few areas of economic life are the returns to good policy so large, or mistakes so costly.

This work covers the substantive law of oil and gas and federal income taxation of oil and gas transactions. The first three chapters examine interests and transactions in the mineral estate. The fourth chapter covers surface and subsurface issues. Chapters five through eight examine in detail the oil and gas lease. Chapter nine addresses the issue of transfers by the lessor and the lessee. Chapters 10 through 12 are devoted to oil and gas taxation. Students will see that this work gives them quick access to the law of oil and gas and the law of oil and gas taxation.

Mexico has large extractive industries and it traditionally has raised sizable fiscal revenues from the oil and gas sector. A confluence of factors—elevated commodity prices, financial challenges of the state-owned oil company Pemex, and revenue needs for financing social and public investment spending over the medium term—suggest that a review of Mexico’s taxation regimes for natural resources would be opportune, against the backdrop of a comprehensive approach to tackling Mexico’s challenges. This paper identifies opportunities for redesigning mining taxation to increase somewhat the revenue intake while maintaining the favorable investment profile of the sector. It also discusses recent reforms to the oil and gas fiscal regime and future reform considerations, with attention to the attractiveness of investment on commercial terms—an issue that should be placed in the context of an overall reform of Pemex’s business strategy and possibly of the energy sector more generally.