
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.
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)
- The Best Lawyers in America© (BL Rankings, LLC), “Ones to Watch,” Tax Law (Austin), 2023
- Selected to the Texas Rising Stars list, Super Lawyers (Thomson Reuters), 2022
- Texas
- Deals & CasesSeptember 21, 2022
- Deals & CasesSeptember 13, 2022
- Deals & CasesSeptember 6, 2022
- Rankings & AwardsAugust 18, 2022
- Deals & CasesAugust 2, 2022
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- Deals & CasesJuly 20, 2022
- Deals & CasesJune 27, 2022
- Deals & CasesJune 22, 2022
- Deals & CasesMay 5, 2022
- Deals & CasesApril 28, 2022
- Deals & CasesApril 27, 2022
- Deals & CasesApril 14, 2022
- Rankings & AwardsMarch 29, 2022
- Deals & CasesMarch 16, 2022
- Deals & CasesMarch 9, 2022
- Deals & CasesFebruary 2, 2022
- Press ReleaseJanuary 11, 2022
- Deals & CasesDecember 20, 2021
- Deals & CasesDecember 14, 2021
- Deals & CasesDecember 6, 2021
- Deals & CasesNovember 29, 2021
- Deals & CasesSeptember 30, 2021
- Deals & CasesSeptember 27, 2021
- Deals & CasesAugust 16, 2021
- Deals & CasesMay 26, 2021
- Deals & CasesMay 11, 2021
- InsightMay 6, 2021
- Deals & CasesApril 20, 2021
- Deals & CasesMarch 19, 2021
- Deals & CasesMarch 15, 2021
- Deals & CasesMarch 9, 2021
- Deals & CasesMarch 3, 2021
- Deals & CasesMarch 2, 2021
- Deals & CasesFebruary 22, 2021
- Deals & CasesFebruary 11, 2021
- Deals & CasesJanuary 28, 2021
- Deals & CasesJanuary 25, 2021
- Deals & CasesJanuary 22, 2021
- Deals & CasesJanuary 14, 2021
- Deals & CasesJanuary 6, 2021
- Deals & CasesJanuary 5, 2021
- “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)