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Gary R. Huffman
Gary R. Huffman
Partner — Tax
Partner — Tax

Gary R. Huffman

Gary R. Huffman
Washington

2200 Pennsylvania Avenue NW
Suite 500 West
Washington, DC 20037

start quote symbolTo be a really effective tax lawyer, you have to have a very high level of technical competence but also be able to contextualize matters for your clients—to explain complex tax issues in a way that makes sense so that they can make the right business decisions. I love working with my clients to help them do that.end quote symbol
Gary R. Huffman

Experience Highlights

  • Marathon Petroleum Corporation, the controlling owner of MLPX LP and Andeavor Logistics LP, as special tax counsel in MPLX LP’s $14 billion acquisition of Andeavor Logistics LP, creating a combined midstream and logistics MLP with an estimated $55 billion enterprise value

  • Energy Transfer Partners in the $60 billion merger with Energy Transfer Equity in a unit-for-unit exchange 

  • Global Atlantic Financial Group in the $1.175 billion acquisition from Southern Power of a 33 percent minority interest in its solar portfolio (comprised of 26 operating solar facilities representing approximately 1.7 gigawatts of capacity)

  • International Paper Co. in the transfer of its $1.8 billion North American consumer packaging business to a joint venture with Graphic Packaging Corp. 

  • Anadarko Petroleum Corporation in its issuance of $460 million of Tangible Equity Units

  • Sunoco Logistics Partners LP in its $20 billion merger with Energy Transfer Partners in a unit-for-unit transaction

  • A large international energy company in the spin-off of its California oil and gas business into an independent and separately traded company

  • Marathon Oil Corporation in the spin-off of midstream and refining assets into Marathon Petroleum Corporation

  • Special Tax Counsel to Hess Midstream Partners in its $391 million initial public offering

  • Western Gas Partners LP in its initial public offering of 7.5 million common units

  • Oil States International in the $2.6 billion spin-off of its accommodations business into Civeo Corporation

  • Energy XXI in its $2.3 billion acquisition of EPL Oil & Gas Inc., creating the largest publicly traded independent oil and gas producer on the Gulf of Mexico Shelf

Credentials

  • The University of Texas at Austin School of Law, J.D., 1988 (Order of the Coif)
  • The University of Illinois, B.S., Accounting with high honors, 1985
  •  Legal 500 U.S., Domestic Tax, 2015; Tax: International Tax, 2014, 2019, and 2021; Tax Controversy, 2013–2015; Tax: US Taxes–Non-Contentious, 2018 and 2021; Tax: US Taxes–Contentious, 2020 and 2021
  • Chambers USA, Tax (District of Columbia), 2015 and 2018
  • The Best Lawyers in America© (BL Rankings, LLC), Tax Law (Washington), 2020–2022
  • District of Columbia
  • Texas
  • U.S. Tax Courts
  • “Advanced Basis Issues: Impact of Liabilities,” PLI’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2021 Part One: The Structural Framework of Subchapter K, May 10, 2021 (speaker)
  • “Advanced Basis Issues: Impact of Liabilities,” PLI Tax Planning for Domestic Foreign Partnerships LLCs Joint Ventures Other Strategic Alliances, April 30, 2019 (presenter)
  • “The New Limitation on the Deduction for Business Interest Expense Under Section 163(j),” Tax Executives Institute TEI 2019 Mid-Year Conference, April 1, 2019 (panelist)
  • “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018 (New York),” May 15, 2018 (speaker)
  • “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018 (Chicago),” May 1, 2018 (speaker)
  • “An Update on Tax Reform and Its Implications in 2018,” Energy Series, V&E Houston Office, February 13, 2018 (speaker)
  • “New Proposed Regulations for BBA Partnership Audits Allow for Push Out Elections in Tiered Partnerships,” V&E Tax Update E-communication, December 19, 2017 (co-author)
  • “The New Era of Partnerships As Taxpayers,” American Investment Council, September 28, 2017, (co-author)
  • “A Greek Company Mines for Magnesite and Strikes Gold for Inbound Investors,” V&E Tax Update E-communication, July 17, 2017 (co-author)
  • “7-Eleven Asset Acquisition,” Corporate Counsel Magazine, July 2017 (co-author)
  • “New Disguised Sale Guidance Presents Major Change for Partnership Transactions,” V&E Tax Update E-communication, October 4, 2016 (co-author)
  • Federal Taxation of Partnerships and Partners, Warren, Gorham & Lamont, 4th edition, 2007 (co-author)
  • “Analyzing Tax-Related Provisions of Partnership Agreements From the Perspective of the Lawyer Who Drafts Them and the Accountant Who Has to Live With Them,” Southern Federal Tax Institute, October 2014 (co-author)
  • “Tiers in Your Eyes: Peeling Back the Layers on Tiered Partnerships,” Taxes – The Tax Magazine, vol. 86, no. 3: 179-220; 258-260, March 2008 (co-author)
  • “Partnership Dispositions of Stock in Controlled Foreign Corporations,” Tax Notes, vol. 110, no. 11: 1319-1344, March 2006 (co-author)
  • “Analysis of the Administration’s Partnership Proposals,” Tax Notes, vol. 84, no 1: 103-140, July 1999 (author)
  • “Oil & Gas Industry,” Practising Law Institute’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, 2017
  • “Oil & Gas Industry,” Practising Law Institute’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, 2016
  • “Dramatic Changes to Partnership Audit Rules and Their Implications for Existing Partnerships,” V&E Tax Update E-communication, November 5, 2015 (co-author)
  • “Oil & Gas Industry,” Practising Law Institute’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, 2015
  • “Non-Compensatory Partnership Options, Convertibles, Recapitalizations and Similar Transactions,” Practising Law Institute’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, New York, New York, May 20, 2014
  • “Special Issues of Tiered Partnerships,” Practising Law Institute’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, New York, New York, May 22, 2014
  • “Taxation of Mining Partnerships,” 22nd Annual Ernst & Young LLP Taxation of Mining Operations Conference, New Orleans, Louisiana, November 14, 2013
  • “Trends in Energy Transactions,” V&E Client Presentation, Houston, Texas, November 7, 2013
  • “Non-Compensatory Partnership Options,” 29th Annual Texas Federal Tax Institute, San Antonio, Texas, June 7, 2013
  • “Non-Compensatory Partnership Options, Convertibles, Recapitalizations and Similar Transactions,” PLI’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, New York, New York, May 21, 2013