“I believe my clients value two attributes in transactional attorneys: deep and long-term industry experience and an understanding of the business results being sought in their transactions. This drives me to be responsive to their needs for creative investment structures and advice that delivers the value they seek.”
John Bradford practices energy and natural resources taxation, finance, and corporate law at the state, federal, and international levels. He advises clients on the tax and business consequences of specific acquisitions, dispositions, financings, joint ventures, hedging activities, and day-to-day business operations.
In both the domestic and the international arenas, John focuses on helping investors design appropriate structures for investments in the U.S and overseas. This includes assisting in the structure of complex energy and natural resources joint ventures, asset acquisitions and dispositions, and structured financings. He also advises clients on drafting their contractual arrangements to optimize US and host country taxation.
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.