Stephen A. Kuntz
Norton Rose Fulbright US LLP
Stephen A. KuntzvCard
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Steve's practice includes all areas of business taxation, with particular emphasis on the tax aspects of transactions involving corporations, partnerships and limited liability companies. He advises clients on the tax consequences of mergers and acquisitions, tax-free reorganizations, spin-offs and divestitures, restructurings, and private equity, as well as the formation and operation of corporations, partnerships and limited liability companies. Steve also advises on a wide array of state and local tax matters, including property tax incentives and exemptions, such as property tax abatement agreements, payment in lieu of tax agreements, industrial district agreements, property tax exemptions, and agreements relating to the limitation of appraised value for school district property tax purposes.
Steve also has substantial experience representing clients in connection with executive compensation planning and negotiations, federal excise tax issues in the energy sector, and Texas tax-legislative matters. In addition, he represents clients in contested tax matters before federal, state and local tax authorities and federal and state courts. Steve's tax controversy practice includes representation of clients in Texas property tax contested matters including owners and operators of refineries, chemical plants, power plants, and industrial and commercial properties. Steve is a member of the Tax Section and its Energy, Employee Benefits, and Technology & Emerging Companies Practice Groups. Before attending law school, Steve was a manager in the tax department of Peat, Marwick, Mitchell & Co. (now KPMG).
JD, with honors, The University of Texas at Austin School of law, 1984
MPA (Masters in Professional Accounting), The University of Texas at Austin Graduate School of Business,1978
BBA, Accounting, cum laude, The University of North Texas, 1977
Admitted to practice: Texas, 1984; U.S. Tax Court; U.S. Court of Federal Claims; U.S. District Courts; Fifth and Federal Circuit Courts of Appeal
- Texas State Bar
- Advising an oil & gas company with respect to a potential internal restructuring valued at over US$1 billion. There are a number of permanent establishment and cross-border issues involved.
- Advising a multinational information technology company based in California on numerous federal income tax controversy matters and a dispute involving a tax sharing agreement. The amount in controversy exceeds US$1 billion.
- Advising an oil & gas company on an IRS audit involving transfer pricing issues. Following an appeals conference and Joint Committee review, the case resolved with the client receiving a refund.
- Representing an oil & gas company before the US competent authority with respect to foreign tax assessments and potential assessments valued at over US$200 million; in a transfer pricing dispute involving a foreign government; and in 13 other audits by tax authorities.
- Representing an offshore drilling company in the application for a bilateral advance pricing agreement between the United States and Australia, and in tax disputes with two other foreign governments.
- Advising an oil & gas company on a refund claim for research credit in excess of US$30 million involving federal and state tax matters, and with respect to a potential global restructuring and conducting due diligence on various other projects.
- Advised Flotek Industries, Inc. (Flotek) on its US$34.4 million acquisition of JP3 Measurement, LLC (JP3), a privately held leading data and analytics technology company, in a cash-and-stock transaction.
- Advised on the economic development tax incentives for a major oil & gas company's project to expand its Baytown, Texas chemical plant.
- Representing a client in connection with tax abatement agreements, Chapter 313 appraised value limitation agreements, industrial district or other non-annexation agreements, tax incentive and economic developments agreements with taxing authorities relating to projects at the Port Arthur Refinery.
- Advising on the tax aspects related to a major energy company's new petrochemical investment.
- Chambers USA, Texas: Tax, Chambers & Partners, 2018 - 2020
- Client Choice Award, Texas: corporate tax, Lexology and International Law Office, Globe Business Publishing Ltd., 2015
- Legal 500 US, recommended lawyer, Tax - US taxes: contentious, The Legal 500, 2018, 2020
- Legal 500 US, recommended lawyer, Tax - US taxes: non-contentious, The Legal 500, 2018
- Legal 500 US, recommended lawyer, Tax: International tax, The Legal 500, 2017
- Legal 500 US, recommended lawyer, Tax: Domestic, The Legal 500, 2015
- The Best Lawyers in America, Best Lawyers, 2003 - 2021
- Texas Super Lawyer, Tax, Thomson Reuters, 2003 - 2004, 2008 - 2020
- Texas Top Rated Lawyer, LexisNexis Martindale-Hubbell, 2012 - 2014
- Co Author, "Texas Comptroller Announces “Fresh Start” Tax Amnesty For Businesses", Fulbright Alert, March 16, 2012
- Co Author, "Texas Comptroller Announces "Fresh Start" Amnesty Program", Fulbright ALERT, April 24, 2007
- Member: Section of Taxation of the American Bar Association, State Bar of Texas, and Houston Bar Association
- Speaker and Panelist: numerous conferences and seminars, including those sponsored by the American Bar Association Section of Taxation, Tax Executives Institute, State Bar of Texas, and Houston Bar Association Sections of Taxation and Real Estate
- Member: American Institute of Certified Public Accountants and Texas Society of Certified Public Accountants