Lee Schnabel

713.651.2933

Notable Experience

He has represented clients before the Internal Revenue Service on audit, administrative appeal, and for private letter ruling requests. He also represents lenders in ad valorem tax disputes.

John has extensive experience in the energy and natural resources industry, having practiced for more than 18 years as a tax lawyer for Exxon Corporation (now ExxonMobil Corporation), having worked in energy and natural resource investment banking at JP Morgan Securities, and having most recently advised clients as a principal in KPMG LLP’s Washington National Tax practice.

Some of John’s recent domestic investment experience includes:

  • Advised a petroleum processing startup company by originating and executing its limited liability company agreement and by structuring and executing the raising of its first round of development capital.
  • Advised an oilfield services company in bankruptcy by filing its protest to several IRS adjustments to its federal partnership tax return and resolving the adjustments in an IRS Appeals Conference.
  • Advised an independent oil and gas company on the tax and business aspects of its acquisition of a large producing oil and gas lease in Texas.
  • Advised an international company on the sale of an undeveloped oil and gas lease in the Gulf of Mexico by assisting in the drafting and execution of the purchase and sale agreement and by providing tax advice on the sale.
  • Advised a refining and marketing company on the structuring and execution of a joint venture through a limited liability company organized to acquire and operate retail service stations.  Provided the client with a post-closing tax opinion on the various aspects of the transaction.
  • Advised a domestic working interest owner on the tax and business consequences involved in structuring a letter of intent for an earning and joint development agreement.
  • Advised a domestic refining and marketing company on the tax and business consequences of restructuring of a joint venture to provide for continuity of ownership and succession planning.
  • Advised a domestic company on the tax and business consequences of a disposition of its interests in limited liability companies and partnerships holding domestic oil and gas properties
  • Advised a domestic refining and marketing company on the tax aspects of its opportunity to acquire additional domestic marketing properties.

Recent inbound and outbound investment experience includes:

  • Advised a domestic oilfield services company on the structure of and documentation for a cross-border research and development agreement in order to optimize US tax results.
  • Advised an international client on its US tax obligations with respect to the engagement of a foreign consulting group to perform services in the US.
  • Advised a multi-national oil and gas company doing business overseas on the drafting of tax provisions of its master service agreement to be used with contractors.
  • Advised South American investors on the U.S. corporate and tax issues involved in purchasing membership interests in a domestic limited liability company.
  • Advised a domestic company on the tax and business consequences of restructuring of ownership of its domestic subsidiary conducting business in the Far East.
  • Advised a foreign limited company on the U.S. corporate and tax issues involved in the company’s acquisition of all of the outstanding stock of a U.S. target corporation; assisted the foreign limited company and its foreign counsel in completing the transaction.
  • Advised a foreign limited company on the structuring and tax aspects of its acquisition of all of the membership interests in a domestic limited liability company classified as a subchapter S corporation.
  • Advised a foreign limited company on the tax and corporate finance aspects of its term loan financing for oil and gas producing properties in Eastern Europe.

John is a frequent speaker on energy and natural resource taxation matters, having presented to the American Petroleum Institute Federal Tax Forum, the University of Texas Parker C. Fielder Oil and Gas Tax Conference, the Institute for Energy Law, the North American Petroleum Accounting Conference, the Texas Federal Tax Institute, the Rocky Mountain Mineral Law Foundation, the Tax Executives Institute, the American Bar Association Section of Taxation Energy and Environmental Taxes and Banking and Savings Institutions Committees, the American Bar Association Business Law Section, the Houston Bar Association Tax and Oil and Gas Sections, the South Texas College of Law Energy Symposium, KPMG LLP’s Global Energy Conference, and the Liskow & Lewis Energy Law Seminar.

John’s articles have been published by The Journal of Taxation, the Rocky Mountain Mineral Law Foundation, Oil, Gas & Energy Quarterly, Oil and Gas Financial Journal, The University of Houston Business and Tax Law Journal, the University of North Texas Institute of Petroleum Accounting Petroleum Accounting and Financial Management Journal, and the KPMG Global Energy Institute.

John has been a guest lecturer on oil and gas taxation at Georgetown University School of Law and currently is Adjunct Professor at the University of Illinois College of Law, where he teaches a seminar class on Energy and Natural Resource Transactions.

Involvement

  • The Foundation For Natural Resources and Energy Law - Member
  • State Bar of Texas, American Bar and Houston Bar Associations – Member, ABA Section of Taxation Partnerships Committee and ABA Business Law Section, Energy Business Committee
  • Houston Energy Finance Group – Member

Recognition

  • Houston Business Journal, "Who's Who in Energy in Houston," November 2011
  • University of Texas Parker C. Fielder Award Recipient for Achievement in Oil and Gas Taxation, November 19, 2015

Credentials

Education

  • University of Houston Law Center (LL.M., 1991)
  • University of Illinois College of Law (magna cum laude, 1980)
  • University of Illinois (B.S., 1977)
    • Bronze Tablet

Bar Admissions

  • Texas, 1980

Presentations

  • "Current Issues and Considerations in Oil and Gas Taxation - New Twists on Established Concepts," North American Petroleum Accounting Conference (NAPAC), May 14-15, 2026, Dallas, Texas
  • “Current Issues and Considerations in Oil and Gas Taxation: New Twists on Established Concepts,” Parker Fielder 2025 Oil, Gas, and Energy Taxation Symposium, November 19, 2025, Houston, Texas
  • "2025 Tax Recent Tax Reform Update"," Liskow's 2025 Tax Update Lunch & Learn, May 19th, 2025, Houston, Texas
  • "An Energy Transactions Smorgasbord: Updates on Transaction Structures for Oil and Gas, Renewable and Clean Energy, and Battery Storage," 16th Biennial Parker C. Fielder Oil, Gas, and Energy Tax Conference, November 16-17, 2023, Houston, Texas
  • “2021 Federal Offshore Update,” Liskow & Lewis Webinar, February 10, 2021
  • Panel Speaker and Slide Deck Author, “Creative Alternatives for Lenders and Producers in Dealing with Reserve-Based Loans,” Institute for Energy Law Webinar, September 23, 2020
  • "What Every Bankruptcy Lawyer Should Know about the Tax Cuts and Jobs Act of 2017," University of Texas 37th Annual Jay Westbrook Bankruptcy Conference, November 15, 2018
  • Structuring Oil and Gas Property Purchase and Sale Agreements: Key Considerations and Provisions, Strafford Webinar, August 9, 2018
  • “Oil and Gas Partnership Allocations and Distributions: A Focus on Capital Account Maintenance and Tax Return Reporting," 44th Annual North American Petroleum Accounting Conference, Dallas, Texas, May 18, 2018
  • “The Impact of 2017 Tax Reform on Energy Industry Mergers and Acquisitions – What We have learned So Far,” The Institute for Energy Law’s Fifth Mergers & Acquisitions in Energy Conference, Houston, Texas, May 17, 2018
  • Panel Speaker – The Impact of 2017 Tax Reform: Industry Winners and Losers, April 26, 2018
  • Presenter – Oil and Gas Taxation, 2018 TEI Houston Chapter Tax School, February 28, 2018
  • Presenter – Tax Planning for Joint Operations to the attendees, Rocky Mountain Mineral Law Foundation Special Institute on Joint Operations and the New AAPL Form 610-2015 Model Form Joint Operating Agreement, Denver, Colorado, December 5, 2017
  • Moderator and Panel Speaker – Partnership Allocation Issues: An analysis of Functional Allocations, Target Allocations and the New Disguised Sale Regulations, 14th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, Houston, Texas, November 16, 2017
  • "A Conversation On U.S. Shale," Featuring Luciano Di Fiori of Energy Insights by McKinsey, Liskow & Lewis Houston Forum Series, June 15, 2017
  • Moderator and Panel Speaker – Structuring Oil and Gas Joint Exploration, Development and Production Operations: Contractual Joint Venture, LLC or LP?, American Bar Association Business Law Section Meeting, New Orleans, Louisiana, April 6, 2017
  • Presenter – Tax Planning for Joint Operations, Rocky Mountain Mineral Law Foundation Special Institute on Joint Operations and the New AAPL Model Form 610 – 2015 Model Form Operating Agreement, Houston, Texas, November 3 and 4, 2016
  • Presenter – Tax Provisions and Considerations for Oil and Gas Property Purchase and Sale Agreements, Rocky Mountain Mineral Law Foundation Special Institute on Oil and Gas Agreements: Purchase and Sale Agreements, Santa Fe, New Mexico, May 12 and 13, 2016
  • Panel Speaker – Tax Planning in a Low Oil Price Environment, Tax Executives Institute 2016 Tax School, Houston, Texas, February 17, 2016
  • Moderator and Panel Speaker – Oil and Gas Property Purchase and Sale Transactions, 13th Biennial Parker C. Fielder Oil and Gas Tax Conference, November 19 and 20, 2015
  • Presenter – Structuring Oil and Gas Farmout Transactions for Financial, Operational and Tax Efficiencies, Liskow & Lewis Breakfast Series, November 3, 2015
  • Panel Speaker – Selected Topics Regarding Oil and Gas Farmout Transactions, Tax Executives Institute 2015 Tax School, Houston, Texas, February 25, 2015
  • Panel Speaker – Financing Oil and Gas Properties, American Bar Association Section on Taxation Mid-Year Meeting, Houston, Texas, January 30, 2015
  • Moderator and Panel Speaker – Selected Topics Regarding Oil and Gas Farmout Transactions, Texas Federal Tax Institute: TexFed Oil & Gas Tax, Inaugural Conference in New York City, New York, November 3–4, 2014
  • Presenter – Energy Joint Ventures, EUCI Course, Houston, Texas, September 22 and 23, 2014
  • Presenter – Structuring Private Partnerships in the Oil and Gas Industry, Practising Law Institute Seminar on Tax Planning for Domestic and Foreign Partnerships, LLCs, Joint Ventures and Other Strategic Alliances, May 2, May 22 and June 12, 2014
  • Presenter – Selected Topics: Taxation of Oil and Gas Partnerships, University of Houston Tax and Business Law Journal Spring Symposium, April 2014
  • Moderator and Panel Speaker – Oil and Gas Farmout Transactions: Planning for the Key Tax Issues in the Lifecycle of the Trade, 12th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, November 2013
  • Presenter - “Post Election Hangover: Where do Federal Taxes Go from Here?”, Liskow and Lewis Breakfast Seminar, January 2013
  • Moderator and Panel Speaker – Current Issues and Trends in Acquisitions and Dispositions of Oil and Gas Properties, 11th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, October 2011
  • "What's Next for Oil and Gas Companies in the Federal Tax and Budget Debate?", Liskow & Lewis Energy Law Seminar, October 2011
  • Moderator and Panel Speaker - Case Study: Structuring Oil and Gas Deals - Industry Conventions, Economics and Tax Issues, 10th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, October 2009
  • Panel Speaker - Damn the Torpedoes: Continuing to Finance U.S. Oil and Gas Operations in Tumultuous Times, 55th Annual Rocky Mountain Mineral Law Institute, July 2009
  • Panel Speaker - Enhanced Oil Recovery and Carbon Sequestration: Sections 193 and 45Q and Beyond, 75th Annual American Petroleum Institute Federal Tax Forum, April 2009
  • Panel Speaker - Economic Planning for Projects and the Role of the Tax Department, 74th Annual American Petroleum Institute Federal Tax Forum, April 2008
  • Presenter - Tax Planning for Joint Operations: Keeping the After-Tax Economics of the Trade Intact, Rocky Mountain Mineral Law Foundation Special Institute on Oil and Gas Agreements: Joint Operations, March 2008, December 2007, and May 2007, Houston Bar Association Oil and Gas Section 2007
  • Presenter - Upstream Federal Tax Issues, South Texas College of Law 20th Annual Energy Law Institute, November 2007
  • Panel Speaker - Fundamentals of Oil and Gas Trading/Hedging Transactions, American Bar Association Section of Taxation May Meeting, May 2006
  • Panel Speaker - Energy Trading and Hedging, 8th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, October 2005
  • Panel Speaker - Financing Oil and Gas Operations: Domestic and International Issues, 7th Biennial University of Texas Parker C. Fielder Oil and Gas Tax Conference, October 2003

Publications

After Hours

“In recent years I have picked up a new sport -bowling. My wife and I participate in a year round league, and we regularly participate in tournaments around the country. I’m an avid sports fan, and bowling provides an outlet that includes a great social component. In addition, I enjoy golf, reading and listen to music."

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