March 4, 2008
Bryan Cave LLP Chicago Partner Daniel Cullen, co-leader of Bryan Cave’s Tax Advice & Controversy Practice, tackles the topic of oil and gas working interests as Section 1031 replacement property in the latest issue of Real Estate Taxation. A frequent author and speaker on complex tax issues, Cullen has advised clients on a number of Section-1031- driven oil and gas syndications, and notes that these transactions require careful planning.
“Investing in oil and gas working interests as ‘replacement property’ in connection with a Section 1031 like-kind exchange raises a number of issues that must be closely evaluated and almost always requires a careful review (and possible restructuring) of the key operative documents,” he writes. “If the parties are willing to be flexible in how they structure the investment, many oil and gas working interest investments have the potential to be qualifying replacement property under Section 1031.”
Cullen focuses his practice in tax advice and corporate finance, including real estate capital markets transactions, structured finance and joint ventures and partnerships. Additionally, he is an adjunct professor of tax law at the DePaul University College of Law.
Click on the attachment below to read his full article, published in the first quarter 2008 edition of Real Estate Taxation.