Energy - Tax


It is critical for businesses to stay vigilant and informed on ways to prepare and maximize value to their bottom line. Blank Rome’s tax attorneys represent energy companies in sophisticated transactions, complex tax controversies, and other matters having federal, state and local, and foreign tax implications.

We assist energy companies, public utilities, and independent power producers with their most significant tax planning concerns, in particular those related to navigating the state and federal regulatory issues impacting the tax aspects of energy transactions. Our combination of government, finance, and legal experience allows us to provide innovative and proactive tax advice to keep our clients ahead of the shifting tax environment.

How We Can Help

  • Evaluating current tax posture and quantifying the impact of potential investments, acquisitions, divestitures, and other corporate structural changes
  • Preparing merger and acquisition tax due diligence reports developing and implementing strategic planning to achieve tax-efficient ongoing legal structures and exit alternatives
  • Negotiating tax incentives and credits with state and local taxing authorities
  • Spearheading and assessing loss contingencies in connection with FIN 48 compliance
  • Preparing legal opinions
  • Preparing and requesting letter rulings from federal, state, and local government authorities
  • Complying with U.S. laws affecting foreign investors (e.g., FIRPTA and CFIUS processes

We also advise on tax controversies and litigation, principally involving disputes with the Internal Revenue Service, Comptroller of Maryland, New Jersey Division of Taxation, New York State Department of Taxation and Finance, New York City Department of Finance, Ohio Department of Taxation, Pennsylvania Department of Revenue, and Philadelphia Department of Revenue.


  • Represented Duquesne Light Company, Duquesne Energy Inc., Toledo Edison Company, Ohio Edison Company, Pennsylvania Power Company, and Cleveland Electric Illuminating Company in significant matters before the Pennsylvania Commonwealth Court.
  • Successfully resolved significant Pennsylvania tax issues for Duke Energy, PECO Energy, New Jersey Natural Gas Company, and Duquesne Light Company.
  • Represented PECO Energy in a Pennsylvania tax matter in which more than $60 million is at issue.
  • Represented New Jersey Natural Gas Company in matters before the New Jersey Tax Court and have represented Dayton Power & Light Company in Ohio tax matters.
  • Represented an international oil company in the successful representation of terminal and refinery facilities in securing major reductions in real estate tax assessments.