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Allyson Seger
Allyson Seger
Counsel — Tax
E: aseger@velaw.com T: +1.512.542.8467
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Counsel — Tax

Allyson Seger

Allyson Seger
Austin
T: +1.512.542.8467
F: +1.512.236.3202

200 West 6th Street
Suite 2500
Austin, Texas 78701

E: aseger@velaw.com
VCard BIO PDF
Allyson Seger

Allyson’s practice focuses on the U.S. federal income tax aspects of complex cross-border and domestic transactions. 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 

  • Huntsman Corporation in its $522 million initial public offering of Venator Materials plc, a global chemical company incorporated in the UK

  • 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

  • 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

  • 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 

  • 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

Credentials

  • 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)
  • Texas
  • “Tax and Accounting Year-End Update,” V&E Austin Office, December 5, 2019 (presenter)
  • “Transactional Look at Outbound Transfers and Section 367,” Tax Executive Institute – Houston Chapter, May 9, 2018 (panelist)

News & Insights

Press Release
Vinson & Elkins Elects 24 New Counsel
January 11, 2022
Deals & Cases
Focus Financial Partners Prices $200M Class A Common Stock Offering
December 20, 2021
Deals & Cases
Chart Industries Acquires Earthly Labs
December 14, 2021
Deals & Cases
Zilliant, Inc. Acquired by Madison Dearborn Partners
December 6, 2021