Gary R. Huffman

Senior Partner

Tax

“To 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.”

Gary R. Huffman

Overview

Gary Huffman’s practice focuses on domestic and international tax planning, tax transactions, and litigation, with an emphasis on partnerships, financial products and natural resources. For more than 30 years, Gary has advised major multinational corporations, including some of the world’s largest banks and oil and gas exploration and production companies, on inbound and outbound cross-border transactions. He has a depth of experience in handling the tax aspects of structuring and raising capital for master limited partnerships (MLPs). Gary has led major corporate acquisitions, dispositions, and spin-off transactions, and has structured countless strategic alliances and joint ventures around the globe.

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Experience

  • 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

Education

  • 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

Admissions

  • District of Columbia
  • Texas
  • U.S. Tax Courts

Recognitions

  •  Legal 500 U.S., Domestic Tax, 2015; Tax: International Tax, 2014, 2019, 2021, 2022 and 2024; Tax Controversy, 2013–2015; Tax: U.S. Taxes: Non-Contentious, 2018, 2021–2026; Tax: U.S. Taxes: Contentious, 2020–2024
  • Chambers USA, Tax (District of Columbia), 2015 and 2018
  • The Best Lawyers in America© (BL Rankings, LLC), Tax Law (Washington), 2020–2027
Insights

Client Alerts

Tax Law (and Controversy) Under the Trump Administration

As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the focus of the Trump administration in the coming months, including the extension of certain expiring provisions of the Tax Cuts and Jobs Act of 2017 (the “TCJA”), changes to the Inflation Reduction Act of 2022 (the “IRA”), increased tariffs, and changes to enforcement priorities at the Internal Revenue Service (the “IRS”).

March 6, 2025

March 6, 2025 • 10-minute read

Highlights of Key Financial Assistance Programs and Tax Benefits for Businesses Under the CARES Act Background Decorative Image

Client Alerts

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”

January 13, 2025 • V&E Tax Update

January 13, 2025 • 4-minute read

Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax Background Image

Client Alerts

“The Ball is in Congress’ Court”: U.S. Supreme Court in Corner Post Paves the Way for Challenges to Longstanding Treasury Regulations

In the final decision of the Supreme Court’s term, the Court again considered the Administrative Procedure Act (“APA”).

July 3, 2024 • V&E Tax Update

July 3, 2024 • 3-minute read

Watch It on Weight Issues in Washington Background Decorative Image

Client Alerts

“A Massive Shock to the Legal System”: Supreme Court Supermajority Significantly Curtails Administrative Agency Authority in Loper Bright with Momentous Impact on Federal Tax System

In a landmark decision, the Supreme Court has overruled the Chevron doctrine, fundamentally altering the landscape of administrative law and significantly impacting federal tax administration.

July 1, 2024 • V&E Tax Update

July 1, 2024 • 5-minute read

Supreme Court Decision Establishes Important Precedent for Prisoners Seeking Access to Judicial System Background Image

Client Alerts

IRS, Treasury Look to Challenge So-Called Basis-Shifting Transactions, But It Won’t Be Easy

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships.

June 18, 2024 • V&E Tax Update

June 18, 2024 • 4-minute read

Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax Background Image
News & Achievements