Overview

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.

Experience

  • Global Infrastructure Partners in the acquisition of a 50% interest in the multi-billion dollar South Fork and Revolution Offshore Wind Projects from Eversource Energy, including the negotiation of the joint venture arrangements with Orsted for the construction and operation of the projects and all financing arrangements (IJInvestor Joint Venture of the Year, 2024)

  • 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 

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Credentials

Education

  • 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)

Admissions

  • Texas

Recognitions

  • Legal 500 U.S., Tax: U.S. Taxes: Non-Contentious, 2025 and 2026; Tax: International Tax, 2024
  • The Best Lawyers in America© (BL Rankings, LLC), “Ones to Watch,” Tax Law (Austin), 2023–2025
  • Selected to the Texas Rising Stars list, Super Lawyers (Thomson Reuters), 2022 and 2023
Insights

Client Alerts

Could the Sale of Your Company Be Tax-Free? – What Founders and Investors Need to Know About Section 1202 QSBS

Executive Summary:  Section 1202 allows certain taxpayers to potentially exclude up to 100 percent of the amount of any eligible …

July 9, 2026

July 9, 2026 • 5-minute read

News & Achievements