Energy - Tax


We work with our energy clients to deliver value and strategic tax advice with regard to:

  • current tax posture evaluation and analysis of the impact of potential investments, acquisitions, divestitures, and other corporate structural changes
  • merger and acquisition tax due diligence reports
  • tax incentives and credits with state and local taxing authorities
  • strategic planning to achieve tax-efficient ongoing legal structures and exit alternatives
  • assessment of loss contingencies in connection with FIN 48 compliance initiatives
  • legal opinion preparation
  • letter rulings from federal, state, and local governmental authorities
  • compliance with U.S. laws affecting foreign investors (e.g., FIRPTA and CFIUS processes)
  • tax controversies and litigation, principally involving disputes with the Internal Revenue Service, Comptroller of Maryland, New Jersey Division of Taxation, New York State Department of Taxation and Finance, New York City Department of Finance, Ohio Department of Taxation, Pennsylvania Department of Revenue, and Philadelphia Department of Revenue.

Representative Matters

  • Represented Duquesne Light Company, Duquesne Energy Inc., Toledo Edison Company, Ohio Edison Company, Pennsylvania Power Company, and Cleveland Electric Illuminating Company in significant matters before the Pennsylvania Commonwealth Court.
  • Successfully resolved significant Pennsylvania tax issues for Duke Energy, PECO Energy, New Jersey Natural Gas Company, and Duquesne Light Company.
  • Represented PECO Energy in a Pennsylvania tax matter in which more than $60 million is at issue.
  • Represented New Jersey Natural Gas Company in matters before the New Jersey Tax Court and have represented Dayton Power & Light Company in Ohio tax matters.
  • Represented an international oil company in the successful representation of terminal and refinery facilities in securing major reductions in real estate tax assessments.