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Partner Jenny Speck is speaking at the CCUS & Carbon Credits 2025 Conference on December 8 at 2:30 p.m. CT on “What the One Big Beautiful Bill Means for the CCUS Industry.”

On November 20, 2025, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) issued four significant orders addressing crude oil, petroleum products, and natural gas liquids pipelines (collectively, “oil pipelines”) matters: (1) a Notice of Proposed Rulemaking (“NOPR”) for the Five-Year Review of the Oil Pipeline Index (“2026 Index NOPR”) proposing an index level of Producer Price Index for Finished Goods (“PPI-FG”) minus 1.42% for the period (July 1, 2026 to June 30, 2031); (2) an Order denying rehearing and granting oil pipelines remedial relief related to the reinstated oil pipeline index for the period March 1, 2022 to September 17, 2024; (3) an order withdrawing the supplemental notice of proposed rulemaking that proposed to amend the index level to PPI-FG minus 0.21% on a prospective basis from July 1, 2025 until June 30, 2026; and (4) an order denying Airlines for America and the National Propane Gas Association’s petition requesting that the Commission initiate a rulemaking to establish affiliate standards of conduct regulations for oil pipelines.

Stephen Josey and Brie Barry report that recent IRS updates to the fast-track settlement program represent a meaningful move toward more efficient and taxpayer-focused dispute resolution. They note that despite these improvements, additional measures are necessary to reinforce independence and bolster taxpayer confidence.

Vinson & Elkins is a sponsor of the UT Law CLE 2025 Oil, Gas, and Energy Taxation Symposium, taking place Wednesday, November 19 in Houston, Texas.

Partner Jenny Speck is speaking with the Clean Fuels Alliance America (CFAA) Board in Washington, D.C. at 9:15 am on "45Z Transferability."

The Supreme Court held a marathon, nearly 3-hour oral argument yesterday, in what could be the most economically-impactful cases this Term: Learning Resources, Inc. v. Trump and Trump v. V.O.S. Selections (the “Tariff Cases”).

In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions.

On August 15, 2025, the Department of Treasury and the Internal Revenue Service (“IRS”) released guidance for wind and solar facilities under Sections 45Y and 48E (the “Tech-Neutral Tax Credits”) in the form of IRS Notice 2025-42 (the “Notice”).

Stephen Josey and Quentin Manuel examine how the IRS enforces civil tax fraud penalties within the federal tax system, offering practitioners key insights into the legal standards, evidentiary burdens, and practical consequences involved. They explain how civil fraud differs from negligence and criminal tax fraud, highlight the IRS’s reliance on circumstantial evidence and badges of fraud, and outline the significant financial and legal risks taxpayers face when fraud is found. They also address defenses available to taxpayers and emphasize the importance of distinguishing between intentional misconduct and good-faith mistakes in today’s enforcement environment.

As the Trump administration continues to roll out its sweeping tariff policy, the North American energy industry is working to address the effects of the President’s tariff strategy. The Trump administration intends to “unleash American energy,”¹ in part by imposing tariffs designed to remedy what the administration views as unfair trade practices and increase U.S. domestic energy production. The currently imposed and threatened tariffs will inevitably impact the energy industry and its consumers. The particularly relevant tariffs can be defined in two broad categories: (1) sectoral tariffs, in this case, imposed under Section 232 of the Trade Expansion Act of 1962, and (2) the country-specific and “reciprocal tariffs” that the Trump administration has imposed under the International Emergency Economic Powers Act.

On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance certain tax, spending, and debt limit legislation with a simple majority vote in the Senate so long as the legislation does not increase the federal budget deficit outside a 10-year budget window.