She has significant experience advising both private partnerships and joint ventures and publicly-traded partnerships (MLPs) on capital formation, acquisition and recapitalization activities and has served as tax counsel to both issuers and underwriters in connection with numerous MLP initial public and follow-on offerings. Allison also advises clients on federal income tax issues in mergers and acquisitions, including tax-free reorganizations.

Representative Experience

• Represented client in the acquisition of a natural gas and liquids gathering and transportation business in North Texas through the acquisition of the equity interests of the seller’s subsidiaries holding these assets.
• Represented private oil and gas company in multiple significant equity raises.
• Represented private oil and gas company in the acquisition of Mid-Continent oil and gas properties and midstream assets for $1.95 billion.
• Represented Hilcorp Energy Company in the acquisition of Alaska North Slope oil and gas properties from BP PLC.
• Represented Hilcorp Energy Company in the acquisition of South Texas oil and gas properties from major public oil and gas company.
• Represented Hilcorp Energy Company in the formation of a joint venture with the Carlyle Group to develop Utica Shale leases.
• Tax Counsel to underwriters on Susser Petroleum Partners, LP IPO.
• Tax Counsel to Cordillera Energy Partners III in its merger with Apache Corporation.
• Tax Counsel to a large private equity fund in its $1.0 billion joint venture with Alta Energy, L.P.
• Tax Counsel to underwriters on PetroLogistics LP IPO.
• Tax Counsel to LRR Energy, LP.
• Tax Counsel to American Midstream Partners, LP.

• Tax Counsel to underwriters on Oiltanking Partners, LP IPO.
• Tax Counsel to Hilcorp Energy in the sale to Marathon Oil of Eagle Ford properties owned by a joint venture with KKR and affiliated funds for $3.5 billion.
• Tax Counsel to a large private equity fund in its Eagle Ford joint venture with GeoSouthern Energy Corporation.
• Tax Counsel to American Infrastructure Group in connection with the formation of American Midstream Partners L.P. and the acquisition from Enbridge Energy Partners L.P. of several intrastate and interstate pipeline systems.
• Multiple limited partnership follow-on MLP equity and debt public offerings and MLP acquisitions and dispositions.
• Tax Counsel to acquirer, target, controlling sponsor partner or special committee on MLP to MLP mergers.
• Tax Counsel to MLP, controlling sponsor partner or special committee in several MLP IDR restructurings.
• Multiple special and conflicts committee engagements involving MLP acquisitions, dispositions and recapitalizations.

Education
BBA, The University of Texas, with highest honors, 1985

• AK Migration: An Analysis of the Rules Governing Partnership Allocations Section 704(b), 704(c) and 752
• Chief Counsel Memorandum Examines MLP IDR Resets
• Goodbye 2017, Hello Tax Reform
• Say Goodbye to Leveraged Partnership Transactions: New Federal Income Tax Regulations Address Disguised Sales and Allocations of Partnership Debt
• IRS Again Considering MLP Private Letter Rulings
• They’re Here… MLP Qualifying Income Regulations Have Finally Arrived
• Well… MLP Qualifying Income Regulations Were Here…