Overview
Greg Nelson is a partner in the Tax practice of Paul Hastings. He concentrates his practice on federal income taxation, with particular emphasis on the tax issues that relate to corporations and partnerships in the energy sector.
Mr. Nelson regularly counsels clients regarding tax issues related to private equity transactions and publicly traded partnerships. He also works on the tax-efficient structuring of corporate mergers, acquisitions and dispositions, including taxable sales and tax-free reorganizations.
Recognitions
- Recognized as a Leading Lawyer for Tax by Chambers USA, 2007-2022
- Listed in Who's Who Legal - Corporate Tax, 2014-2022
- Listed in The Best Lawyers in America, 2001-2023
Education
- University of Virginia School of Law, J.D., 1981
- George Washington University, B.A., 1978 (Eta Sigma Phi, Phi Eta Sigma)
Representations
- Represented IFM, as special tax counsel, on tax issues arising in IFM’s $10.3 billion acquisition of Buckeye Partner LP
- Represented Lotus Midstream LLC in its acquisition of the Centurion Pipeline system from Occidental Petroleum
- Represented CrossAmerica Partners LP in a $184.5 million asset exchange with Circle K Stores Inc.
- Represented Castex Energy Partners LP in its bankruptcy reorganization, including design of a tax efficient structure for the bankruptcy exit transaction
- Master limited partnership engagements, including CrossAmerica Partners, LP, NuStar Logistics L.P., Atlas Resource Partners LP, Atlas Energy Group, LLC, and Vanguard Natural Resources LLC. Representation includes advice related to the evaluation of qualifying income issues, and the use of tax-efficient techniques for the capitalization of the issuer
- Represented the conflicts committee of Crestwood Midstream Partners LP (NYSE:CMLP) in the $7.5 billion merger of CMLP with Crestwood Equity Partners LP (NYSE:CEQP)
- Represented the conflicts committee of Crestwood Midstream Partners LP (CMLP) in CMLP's joint purchase with Brookfield Infrastructure Group of the Tres Palacios natural gas storage facility from Crestwood Equity Partners LP for $130 million
- Represented CST Brands, Inc. (CST) in the purchase of the general partner and the incentive distribution rights of CrossAmerica Partners LP (CAPL) (formerly Lehigh Gas Partners LP) from the Topper Group
- Represented CST Brands, Inc. (CST) in the sale of 5% limited partner interest in CST’s wholesale fuel supply business to CrossAmerica Partners LP for $50.4 million
- Represented CST Brands, Inc. (CST) in two dropdown transactions to CrossAmerica Partners LP for total consideration of approximately $261.5 million, including sale of the real property associated with recently constructed stores and sale of a 12.5% interest in CST’s wholesale fuel supply business
- Represented CrossAmerica Partners LP (CAPL) in the public offering of 4,600,000 common units representing limited partner interests in CAPL for approximately $159.4 million
- Represented NuStar Logistics, L.P. in public offering of $300 million of its 6.750% senior notes due 2021
- Representing Vanguard Natural Resources, LLC (NASDAQ: VNR) (Vanguard) in the negotiation of a definitive Agreement and Plan of Merger to acquire Eagle Rock Energy Partners, L.P. (NASDAQ: EROC) (“Eagle Rock”), in exchange for common units representing limited liability company interests in Vanguard, implying a transaction value of approximately $614 million, including the assumption of Eagle Rock’s existing debt
- Representing Vanguard Natural Resources, LLC (Vanguard) in the negotiation of a definitive Purchase Agreement and Plan of Merger to acquire LRR Energy, L.P. and its general partner, LRE GP, LLC (the “General Partner”), in exchange for common units representing limited liability company interests in Vanguard, implying a transaction value of approximately $539 million, including the assumption of LRR Energy’s existing debt
- Represented Tall Oak Midstream in the sale of assets to Enlink for $1.55 billion
- Represented Vanguard Natural Resources, LLC in the tax aspects of its bankruptcy reorganization
- Halliburton Company – initial public offering of KBR, Inc., followed by a tax-free exchange offer by Halliburton of shares of KBR common stock for outstanding shares of Halliburton common stock, including obtaining an IRS ruling that the exchange offer was tax-free to Halliburton Company and the exchanging Halliburton shareholders
- Represented TEPPCO Partners, L.P. in its merger with Enterprise Products Partners, L.P.
- Reliance Industries, Inc. -- negotiated the tax aspects of Reliance's investment in Pioneer Natural Resources' Eagle Ford shale properties
- Reliant Energy, Incorporated (now CenterPoint Energy, Inc.) – spin-off of Reliant Resources, Inc., including obtaining an IRS ruling that the spin-off was tax-free to CenterPoint Energy, Inc. and its shareholders
news
- Paul Hastings Advises 2U in Debt Refinancing Transactions - January 9th, 2023
- Spearmint Energy Acquires 150MW Energy Storage Project - July 28th, 2022
- Paul Hastings Launches Interdisciplinary Energy Transition & Infrastructure Team to Help Clients Prepare for Low-Carbon Future - June 9th, 2021
- Paul Hastings Ranked as Top Three Firm for New Rankings and Recognized for Numerous Practice Strength and Growth in Chambers USA 2021 - May 21st, 2021
- Paul Hastings Practices and Lawyers Score Top Rankings in Chambers USA 2020 - May 1st, 2020
- Paul Hastings Practices and Lawyers Score Top Rankings in Chambers USA 2019 - May 1st, 2019
- CrossAmerica and Alimentation Couche-Tard Announce Agreement for Series of Asset Exchanges - December 21st, 2018
- Enable Midstream Partners to Acquire Assets of Velocity Midstream Partners - October 25th, 2018
- Lotus Midstream to Acquire Centurion Crude Oil Pipeline and Related Assets in Texas, New Mexico and Oklahoma from Occidental Petroleum Corporation - August 8th, 2018
- Osprey Energy Acquisition Corp. Acquires Royal Resources Assets from Blackstone in $894 Million Business Combination - June 4th, 2018
- Targa Resources Expands Joint Venture with Sanchez Midstream Partners - May 30th, 2018
- Paul Hastings Practices and Lawyers Score Top Rankings in Chambers USA 2018 - May 11th, 2018
- Great Salt Plains Midstream Acquires Thunderbird Midstream - May 4th, 2018
- MVP Holdings, Energy Spectrum and Chisholm Oil & Gas Announce Formation of STACK Oil and Gas Midstream Joint Venture, Great Salt Plains Midstream, LLC - December 20th, 2017
- Vanguard Natural Resources Successfully Completes Financial Restructuring - August 2nd, 2017
- EnCap Flatrock Midstream and Tall Oak Midstream Announce Formation of Tall Oak Midstream III, LLC - July 19th, 2017
- Paul Hastings Practices and Lawyers Score Top Rankings in Chambers USA 2017 - June 5th, 2017
- Paul Hastings Practices and Lawyers Score Top Rankings in Chambers USA 2016 - June 8th, 2016
- Energy Veteran Joins Paul Hastings in Houston to Lead Oil and Gas Group - January 26th, 2016
- Tall Oak Midstream Sells TOM-STACK, LLC and TOMPC LLC to EnLink Midstream - December 7th, 2015
Recognitions
insights
- Proposed IRS Regulations Significantly Curtail Impact of Section 956 for U.S. Corporate Borrowers - November 5th, 2018
- Tax Reform Provides New Tax Benefits to Unincorporated Businesses - January 12th, 2018
- Real Estate Related Provisions of the Tax Reform Act - January 9th, 2018
- The Tax Cuts and Jobs Act Makes Significant Changes to Taxation of Business Operations - January 8th, 2018
- The International Provisions of the GOP Tax Reform Act - December 28th, 2017
- Tax Cuts and Jobs Act Significantly Impacts Individual Taxation Provisions - December 26th, 2017
- Section 355 Spin-Off Developments: Clarification of “Predecessors” and “Successors” - January 12th, 2017
- IRS Issues Proposed Regulations Regarding Energy Master Limited Partnerships - May 8th, 2015
- IRS Ends Moratorium on Private Letter Rulings Related to Qualifying Income for Master Limited Partnerships - March 9th, 2015
- What are the most significant trends shaping the oil and gas industry today? - May 16th, 2014
- Tax Considerations for Publicly Traded Partnerships - October 7th, 2013
- Delaware Supreme Court Reaffirms MLPs Freedom to Contract Out of Fiduciary Duties - July 31st, 2013
Engagement & Publications
- Delaware Supreme Court Reaffirms MLPs’ Freedom to Contract Out of Fiduciary Duties (July 31, 2013)
- IRS Issues Proposed Regulations Regarding Energy Master Limited Partnerships (May 08, 2015)
- IRS Ends Moratorium on Private Letter Rulings Related to Qualifying Income for Master Limited Partnerships (March 09, 2015)
- National Association of Publicly Traded Partnerships Investor Conference, Federal Tax Update (May 2015)
- Master Limited Partnership Association Investor Conference (June 2016)
- Federal Tax Update (June 2017)
- Tax Issues in the Disposition of Oil & Gas Assets, Chapter 12, Thirty-Third Annual Energy & Mineral Law Institute, Volume I, The Energy & Mineral Law Foundation (June 24, 2012)
- Cancellation of Indebtedness for Publicly Traded Partnerships, Vol. V, LSU Journal of Energy Law and Resources 283 (2017)
Involvement
- State Bar of Texas
- United States Court of Appeals for the Federal Circuit
- United States Court of Federal Claims
- United States Tax Court
- Houston Methodist Hospital System, Chairman, Board of Directors
- Houston Methodist Research Institute, Member, Board of Directors, Former Chairman
- Memorial Assistance Ministries, Member, Board Emeritus, Former Chairman