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Allyson Seger

Allyson Seger Senior Associate, Tax

Allyson’s practice focuses on the U.S. federal income tax aspects of complex cross-border and domestic transactions. She has experience working with clients and other advisers in a broad range of industries, including energy (e.g., oil and gas exploration and production, oilfield services, electric power), petrochemicals, banking and finance, aircraft leasing and sales, medical devices, and real estate. Allyson advises clients with regard to the formation of various inbound and outbound cross-border structures, joint ventures, “Up-Cs” and other initial public offering (IPO) vehicles, and private equity structures. She also advises clients with regard to mergers and acquisitions (M&A), line of equity and credit transactions, and cross-border restructurings. Allyson also has experience in the resolution of tax controversies with the Internal Revenue Service. The following is a list of representative matters in which Allyson has assisted.

Experience Highlights

  • Brigham Minerals, Inc. in its $261 million initial public offering of Class A common stock utilizing an Up-C structure
  • Blackstone Infrastructure Partners in its $3.3 billion acquisition of a controlling interest in Tallgrass Energy 
  • New Fortress Energy LLC in its $291 million initial public offering of Class A shares
  • Focus Financial Partners in an investment by Stone Point Capital and KKR that values Focus at approximately $2 billion
  • Shell Oil Company with regard to tax matters in its split-up of Motiva Enterprises LLC, a joint venture with Saudi Aramco 
  • Buckeye Partners, L.P. in structuring its investment in a 50% stake in the VTTI Group, one of the largest independent global energy terminal businesses, with an implied total value of $2.3 billion 

International Tax

  • Huntsman Corporation in its initial public offering of Venator Materials plc, its domestic and internal pigments business
  • Soros Fund Management in structuring an investment by Quantum Strategic Partners in Zenium Technology Partners, a data center development and management company with facilities located in developed and emerging markets
  • A private equity firm in a $250 million line of equity commitment to fund an international aircraft leasing business
  • Riverstone Holdings in the formation and $525 million line of equity commitment to Sierra Oil & Gas, Mexico’s first independent exploration and production company
  • Talos Energy LLC, as member of a consortium and Operator, in its successful bid for two awarded offshore blocks in Mexico’s first hydrocarbons auction and other matters in respect of their operation and joint ownership
  • Several MLPs with significant investments in non-U.S. assets with respect to acquiring, financing, and holding such assets

IPOs & Equity Offerings

  • Focus Financial Partners Inc. in its $615 million initial public offering of common stock utilizing an Up-C structure
  • Select Energy Services, Inc. in its $122 million initial public offering of common stock
  • Rice Energy Inc. in its $1.1 billion initial public offering of common stock
  • RSP Permian, Inc. in its $448 million initial public offering of common stock

Mergers & Acquisitions

  • Sunoco Logistics Partners LP in its $20 billion merger with Energy Transfer Partners in a unit-for-unit transaction
  • Maxar Technologies in its $3.6 billion merger with DigitalGlobe, creating a leading provider of satellites, earth imagery, geospatial data solutions and analytics
  • Centennial Resource Production in the approximately $1.39 billion sale of the company, a Natural Gas Partners portfolio company, to Silver Run Acquisition Corporation
  • Niska Gas Storage Partners in the $911.9 million sale of the company, a natural gas services provider and Riverstone Holdings portfolio company, to Brookfield Infrastructure 

U.S. Tax Controversy & Litigation

  • A domestic manufacturer in a cost sharing dispute relating to the amount of, and methodology for determining, the buy-in payment for intangibles transferred to foreign affiliates
  • A public company in an “Up-C” structure in a dispute relating to its tax receivable agreements 
  • An offshore drilling contractor in a transfer pricing dispute with IRS; settled at IRS Appeals


Contact Details

Austin

T +1.512.542.8467
F +1.512.236.3202
aseger@velaw.com
2801 Via Fortuna
Suite 100
Austin, TX 78746
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Allyson's Practices

  • Georgetown University Law Center, J.D. cum laude, 2013 (Senior Articles Editor, Georgetown Journal of Law & Public Policy
  • Johns Hopkins University, B.A., English and Economics university and departmental honors, 2008 (Phi Beta Kappa)
  • Admitted to practice: Texas