William Paul Bowers

Of Counsel
Norton Rose Fulbright US LLP

Dallas
United States
T:+1 214 855 3903
Dallas
United States
T:+1 214 855 3903
William Paul Bowers

William Paul Bowers

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Biography

Bill Bowers rejoined the Dallas location as a partner in the Fall of 2008, following two years as Senior Counsel in the Office of Tax Policy of the Treasury Department. In the Office of Tax Policy, he was responsible for the development of administrative guidance and legislative initiatives for pass-through entities. He played an important role in formulating the Administration's response to proposed legislation regarding the taxation of carried interests and the treatment of publicly traded hedge funds and private equity funds as corporations. Also, in his position with the Treasury, he worked closely with the IRS to develop administrative guidance on a number of matters including non-compensatory options, compensatory options, debt-for-equity exchanges, varying interests rules and the application of mixing bowl rules to partnership mergers.

As a member of tax practice group, he focuses on federal income tax planning for complex business transactions involving corporations, partnerships and real estate investment trusts. Additionally, Bill co-authored a Treatise on Texas LLCs, which is supplemented annually, with Patrick O'Daniel and George Coleman. He is an active speaker and author on federal tax issues, partnerships and LLCs.


Professional experience

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LLM, Georgetown University Law Center, 1979
JD, Southern Methodist University Dedman School of Law, 1975
BBA., with honors, Accounting, Texas A&M University, 1972

While attending law school Bill was a member of the Law Review and on the editorial board of the Journal of Air Law & Commerce. He was admitted to practice law in Texas in 1975. He was certified as a public accountant in Maryland in 1978.

  • Texas State Bar
  • US federal income tax planning in connection with the incorporation of an oil and gas limited partnership
  • Pre-organization corporate restructuring to address Section 897 of the Internal Revenue Code of 1986 
  • Reorganization of a partnership investment in a large real estate portfolio
  • Merger of publicly traded partnerships
  • Investments in real estate for tax-exempt organizations
  • Corporate taxable acquisition of businesses including election under Code Section 338(h)(10)
  • Corporate non-taxable reorganization
  • Cross Border Investments in Canada
  • Structuring Oil and Gas Production Payments
  • Planning on Dispositions of Oil and Gas Investments
  • Best Tax Lawyers In Dallas, D Magazine, 2001, 2003 - 2006, 2011 - 2012
  • Chambers USA, Texas: Tax, Chambers & Partners, 2004, 2010 - 2019
  • Who's Who Legal: Recognized for Corporate Tax 2016 – 2018
  • Texas Super Lawyer, tax, Thomson Reuters, 2003 - 2006, 2011 - 2013, 2015 - 2018
  • The Best Lawyers in America, Tax, Best Lawyers, 2006, 2012 - 2020
  • Lawyer of the Year, Dallas Tax Law, Best Lawyers, 2016
  • Legal 500 USA, leading lawyer, Tax - US taxes: non-contentious, The Legal 500, 2018 - 2019
  • Legal 500 USA, leading lawyer, Tax: Domestic tax: central, The Legal 500, 2011 - 2017
  • Legal 500 USA, recommended lawyer, Tax - US taxes - non-contentious, The Legal 500, 2017-2019
  • Co-author with Patrick O'Daniel and George Coleman, "Texas Limited Liability Company: Forms and Practice Manual," Data Trace Publishing Company (first published in 1994 and supplemented annually) 
  • Co-author, "Noncompensatory Options Regulations May Adversely Affect Holders, Buyers, and Historic Partners," Fulbright Briefing, February 14, 2013
  • Bowers & O'Daniel, "Send Not to Know for Whom the Bell Tolls," Canal Corporation, 13 Business Entities 4, September/October 2011
  • Co-author, "Treasury Publishes Long Awaited Guidance on Series LLCs and Cell Companies," Fulbright Briefing, September 24, 2010
  • Co-author, "Treasury Releases Energy Grant Guidance and Application Form," Fulbright Briefing, July 22, 2009
  • Co-author, "New Guidance on Procedure to Make Election to Utilize Energy Credit in lieu of Production Tax Credit," Fulbright Briefing, June 10, 2009
  • Co-author, "Stimulus Act and Renewable Energy: New Tax Incentives and Provisions for Transmission Infrastructure," Fulbright ALERT, February 18, 2009
  • Bowers & Lee, "Warrants and Convertible Preferred Interests for Partnerships and LLCs," P.L.I. Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, 305, 2004
  • Miller & Bowers, "Section 752(c): A Riddle Wrapped in a Mystery Inside an Enigma," P.L.I. Tax Planning For Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, 871, 2004
  • W. Bowers & P. Kinkaid & G. Coleman, Texas Limited Liability Company Forms and Practice Manual, 2d ed., 1995, (supplemented annually)
  • "Loan Workouts and Foreclosures," Texas Society of CPAs Houston Chapter, 1992 Tax Expo, 1992
  • "Limited Liability Company Issues," The University of Texas School of Law Conference on Current Issues in Partnerships, Limited Liability Companies, and Registered Limited Liability Partnerships, 1992
  • Bowers & Stone, "The Section 752 Regulations: A Critical Analysis," Taxes magazine, Vol. 68, Page 99, 1990
  • "Installment Sales," American Bar Association Section of Taxation Midyear Meeting, 1988
  • "Real Estate Dispositions After the 1987 Act," American Bar Association Section of Taxation Spring Meeting, 1988
  • "Tax Consequences of Workouts and Loan Foreclosures," State Bar of Texas, Real Estate Conference, 1988
  • "Recent Developments In Tax Accounting," State Bar of Texas Advanced Tax Law Course, 1988
  • "Important Issues With Master Limited Partnerships," Dallas Bar Association Tax Section, 1987
  • Bowers & Albaral, "Planning to Avoid the Cash Basis Limitation Under the New Temp. Regs," Journal of Taxation, Vol. 67, Page 204, 1987
  • Bowers & Stone, "Some Items Still Deductible Under All Events Test Despite New Economic Performance Rules," Journal of Taxation, Vol. 64, Page 354, 1986
  • "1986 Tax Reform," Dallas Bar Association Tax Section, 1986
  • "1986 Tax Reform," ALI-ABA Program, 1986
  • "Tax-Exempt Leasing and Economic Performance," State Bar of Texas, 7th Annual Advanced Real Estate Law Course, 1985
  • "Accounting Changes - The Tax Reform Act of 1984," Dallas Bar Tax Section, 1985
  • "Tax Accounting Changes - The Tax Reform Act of 1984," ALI-ABA Seminar On The Tax Reform Act of 1984, 1984
  • "Forming, Operating and Dissolving the Closely Held Business," State Bar of Texas, Professional Development Program, 1983
  • "Straddles Do Not Apply to Hedging Transactions But Bar Other Tax Savings," Journal of Taxation, Vol. 56, Page 24, 1982
  • "New Law Eliminates Most Tax Straddles Benefits: An Analysis of The Drastic Changes," Journal of Taxation, Vol. 55, Page 338, 1981
  • "Canal Corporation," University of Texas Annual Tax Conference, December 2011
  • "Hot Topics in Partnerships," PLI, San Francisco, California, June 2011
  • "Canal Corporation," Texas Tax Institute, June 2011
  • "Canal Corporation," Dallas Bar Tax Section, May 2011
  • "Canal Corporation," American Bar Association Tax Section Seminar, April 2011
  • "Canal Corporation," American Bar Association Tax Section, Winter Meeting, January 2011
  • "Carried Interests," University of Texas Annual Tax Conference, December 2010 
  • "The Stimulus Act and DOE Loan Guarantees: A Roundtable Discussion on Where Things Stand," Fulbright & Jaworski L.L.P., July 7, 2009
  • "Recent Development in Partnership Equity for Services," PLI, New York, New York, June 2008
  • "Recent Legislation in Unrelated Business Taxable Income," Tax Section, ABA, Las Vegas, Nevada, February 2008
  • "Selected Issues in Partnership Transactions," Tax Section, ABA, Las Vegas, Nevada, February 2008
  • "Selected Topics for Hedge Funds and Private Equity Funds," Tax Section, New York State Bar, New York, New York, 2008
  • "Current Developments in Partnerships and Real Estate," AICPA, Washington, DC, December 2007
  • "Legislative and Regulatory Developments in Partnership Tax," Tax Section, Dallas Bar, Dallas, Texas, December 2007
  • "Compensatory Partnership Interests," Tulane Tax Institute, New Orleans, Louisiana, November 2007
  • "Hot Topics in Partnership Tax," NYU Real Estate and Partnership Program, San Francisco, California, November 2007
  • "Mixing Bowl Rules for Assets-Over-Mergers," Tax Section, DC Bar, Washington, DC, November 2007
  • "Discussion of Recent Guidance in Wind Energy," Wind Energy Conference, Washington, DC, November 2007
  • "Hot Topics in Partnership Tax," NYU Real Estate and Partnership Program, New York, New York, October 2007
  • "Selected Topics for Hedge Funds and Private Equity Funds," Tax Executives Institute, New York, New York, September 2007
  • "Taxing Carried Interests," Tax Section, DC Bar, Washington, DC, September 2007
  • "Selected Topics in Real Estate Tax," Tax Section, ABA, Vancouver, Canada, September 2007
  • "Current Developments in Real Estate and Partnership Tax," National Association of Real Estate Counsels, Monterey, California, June 2007
  • "Recent Developments in Partnership Equity for Services," PLI, Chicago, Illinois, June 2007
  • "Current Developments in S Corporations," Tax Section, ABA, Washington, DC, May 2007
  • "Review of Section 751(b)," Tax Section, ABA, Washington, DC, May 2007
  • "Tax Aspects of Tenancy-in-Common Programs," Law Conference ICSC US Shopping Centers, 2004
  • "Drafting Techniques: A Parade of Hits," 20th Annual Texas Federal Tax Institute, 2004
  • "Update on Partnership Tax Developments," The University of Texas School of Law, Current Issues Affecting Partnerships, Limited Partnerships and Limited Liability Companies, Austin, Texas, 2003
  • "Update on Partnership Tax Developments," The University of Texas School of Law, Current Issues Affecting Partnerships, Limited Partnerships and Limited Liability Companies, Austin, Texas, 2002
  • "Community Property Issues In Partnerships," Dallas Bar Association Tax Section, Dallas, Texas, 2002
  • "Update on Partnership Tax Developments," The University of Texas School of Law, Current Issues Affecting Partnerships, Limited Partnerships and Limited Liability Companies, Austin, Texas, 2001
  • "Current Developments in Partnership Taxation," State Bar of Texas, Advanced Tax Course, 2001
  • "Update on Partnership Tax Developments," The University of Texas School of Law, Current Issues Affecting Partnerships, Limited Partnerships and Limited Liability Companies, Austin, Texas, 2000
  • "Mergers, Divisions and Conversions: The Transmogrification of Partnerships and LLCs," The University of Texas School of Law, Current Issues Affecting Partnerships, Limited Partnerships and Limited Liability Companies, Austin, Texas, 2000
  • "Convertible and Preferred Partnerships Interests," 15th Annual Texas Federal Tax Institute, 1999
  • "Current Partnership Topics," Fort Worth Chapter Society of CPAs, Tax Institute, Fort Worth, Texas, 1998
  • Current Partnership Topics, State Bar of Texas, Annual Advanced Tax Conference, 1997
  • "Book Ups, Book Downs and Bail Outs - Regulations Under Sections 704(c) and 737," State Bar of Texas, 13th Annual Tax Lax Conference, 1995
  • "Section 704 Regulations With Analysis of Typical Partnership Provisions," State Bar of Texas, 11th Annual Tax Law Conference, 1993
  • "Choice of Entity," The University of Texas School of Law, 41st Annual Taxation Conference, Austin, Texas, 1993
  • "Limited Liability Companies & Limited Liability Partnerships," Austin Chapter Texas Society of CPAs, Austin, Texas, 1993
  • The University of Texas School of Law, Adjunct Professor
  • Georgetown University School of Law, Adjunct Professor
  • Southern Methodist University Dedman School of Law, Former Adjunct Professor in taxation of property transactions
  • American Bar Association - Committee on Tax Accounting Problems, Past Chair
  • State Bar of Texas - Tax Section, Chair (2005 - 2006) 
  • Dallas Bar Association - Tax Section, Past Chair
  • Fellow - American College of Tax Counsel