Represents public and private companies with regard to the U.S. federal income tax aspects of domestic and international transactions.
Significant experience representing clients in the energy industry, including master limited partnerships (MLP).
Partner in charge of the Houston office.
Member of the firm’s partnership admission committee and firmwide diversity & inclusion council; chair of the Houston office women’s professional development initiatives.

Alison advises clients on the federal income tax aspects of business transactions such as mergers, acquisitions, joint ventures and other partnership arrangements; recapitalizations; restructuring (in- and out-of-court); and other financing transactions, with a focus primarily in the energy sector.

She also frequently serves as tax counsel in capital markets transactions, advising public companies (including MLPs) and underwriters in connection with initial public offerings (IPOs), follow-on equity and debt offerings, public mergers and spin-offs.

Furthermore, Alison is the partner in charge of the Houston office.

Representative Work

Represented Aquadrill in its ~$1 billion all-stock merger with Seadrill, a leading offshore drilling contractor.
Advised TWFG Holding Company, LLC in connection with its insurance company spin-off to members and additional capital contributions, including devising the spin-off plan and working with the general counsel’s office and the company’s outside accountant in ensuring a tax-efficient structure.
Represented EOG Resources, Inc. in its $2.5 billion combination with Yates Petroleum Corporation, including providing a related tax opinion regarding the tax-free status of a related spin-off transaction by Yates.
Represented Talos Energy Inc., which through its Talos Low Carbon Solutions division, formed a joint venture with Carbonvert, Inc. and Chevron U.S.A. Inc. to develop the Bayou Bend CCS offshore carbon capture and sequestration hub.
Represented the Ad Hoc Group of First Lien Lenders of Foresight Energy LP in the chapter 11 cases of Foresight Energy LP and its affiliated debtors and debtors in possession.

Represented Sanchez Energy Corporation, a publicly owned independent exploration and production company, and certain of its direct and indirect subsidiaries in its chapter 11 cases pending before Judge Marvin Isgur the United States Bankruptcy Court for the Southern District of Texas, with the intention of restructuring approximately $2.3 billion in total funded debt plus significant onerous contractual liabilities.
Represented Franklin Advisors, Inc. in a restructuring involving Chesapeake Energy Corporation. Chesapeake intends to use the proceedings to strengthen its balance sheet and restructure its legacy contractual obligations to achieve a more sustainable capital structure.
Represented AllianceBernstein in its role as pre-petition administrative agent and lender and administrative agent and lender under the post-petition debtor-in-possession (DIP) financing facility in the Chapter 11 bankruptcy cases of Elk Petroleum, Inc. and certain of its affiliates.
Represented Enterprise Products in its $442 million sale to Altus Midstream Company of a 33% equity interest in the Enterprise subsidiary that owns the Shin Oak Pipeline.
Advised Blackstone in connection to Targa Resources Corp. selling a minority stake in its North Dakota oil and gas assets to Blackstone-affiliated funds in a $1.6 billion deal.
Represented a group of consenting creditors in PetroQuest Energy Inc.’s restructuring support agreement with its first lien lenders and second lien noteholders to permanently reduce its debt and the related interest expense in ways that support the long-term growth and success of the business.
Represented AB Holdings LLC in connection with bankrupt oil and gas driller Elk Petroleum Inc. as it progresses through the Chapter 11 process after allowing certain preferred equity holders to convert their holdings to unsecured debt prior to filing its bankruptcy petition.
Advised Viper Energy Partners LP in its underwritten public offering of 10,925,000 common units. The total gross proceeds of the offering (before underwriters’ discounts and commissions and estimated offering expenses) were approximately $340 million.
Represented long-time client Genesis Energy, LP, with respect to a $350 million preferred equity commitment by certain investment fund entities affiliated with GSO Capital Partners in a subsidiary that generates Genesis trona business.
Counseled Diamondback Energy, Inc. on tax matters in connection with several strategic transactions, including its $740 million drop-down sale of certain mineral and royalty interests to Viper Energy Partners LP, $285 million sale of certain conventional and non-core assets in the Permian Basin, $37 million sale of certain non-core assets in the Permian Basin, $1 billion offering of 2.875% senior notes due 2024 and Diamondbacks acquisition of all public common units in Rattler Midstream.
Advised the holdco facility lenders of Salt Creek Midstream, a full service natural gas gatherer and processor on tax matters related to its comprehensive recapitalization, guiding the foreign and domestic lender group through complex U.S. tax issues, and in negotiating and implementing an optimal structure for the debtor companies and the lenders.
Advised Diamondback Energy, Inc. in a joint venture between global alternative asset manager The Carlyle Group L.P. and Diamondback Energy, Inc. to fund the development of Diamondback’s oil and gas assets in the San Pedro area of Pecos County, Texas, within the Southern Delaware basin.
Advised Rattler Midstream LP on tax issues related to its $765 million initial public offering.
Advised Diamondback Energy, Inc. in connection to its definitive purchase agreement to acquire all leasehold interests and related assets of Ajax Resources, LLC for $900 million in cash and 2.58 million shares of Diamondback common stock, subject to certain adjustments.
Represented Rattler Midstream LP in its acquisition of Reliance Gathering, LLC for $355 million in cash, as part of its joint venture entity with Oryx Midstream, a portfolio company of Stonepeak Infrastructure Partners.
Served as tax counsel to Viper Energy Partners LP in converting its federal income tax status from a partnership to a corporation for tax purposes via a “check the box” election.
Counseled Cimarex Energy Co. on the tax aspects of its $1.6 billion cash and stock acquisition of Resolute Energy Corp.
Served as tax counsel to GSO Capital Partners in the formation of, and in its role as a member of, GEP Hayneville LLC, the consortium of GSO and GeoSouthern Haynesville LLC, in the $850 million acquisition of its Haynesville Shale assets from indirect, wholly owned subsidiaries of Encana Corporation.
Provided tax and structuring advice to an ad hoc group of unsecured noteholders of EV Energy Partners, L.P., an independent oil and gas MLP, in its successful financial restructuring and emergence from Chapter 11 as a new corporation under the name Harvest Oil & Gas Corp.
Guided Genesis Energy, L.P. through tax issues related to its
$1.3 billion acquisition of Tronox Ltd.’s alkali business, the world’s largest producer of natural soda ash.
Served as tax counsel to Stone Energy Corporation in its all-stock merger with Talos Energy LLC, a transaction that created Talos Energy, Inc.
Provided tax advice to the conflicts committee of Archrock Partners LP, a natural gas compression services company, in a definitive merger agreement with its parent corporation, Archrock.
Represented 7-Eleven, Inc., the largest chain in the convenience retailing industry, with regard to the tax aspects of its acquisition of more than 100 gasoline and convenience store locations.
Served as tax counsel for EOG Resources, Inc. in its $2.5 billion merger with Yates Petroleum.
Advised Gulfport Energy Corporation on tax issues related to its $1.85 billion acquisition of oil and natural gas assets from Vitruvian II Woodford, LLC.
Provided tax advice to Diamondback Energy, Inc. in its $2.55 billion acquisition of oil and natural gas assets in the Permian Basin from Brigham Resources LLC and in its $560 million acquisition of oil and gas assets in the Southern Delaware Basin.
Advised an MLP client on the tax ramifications of a $142 million public offering of 4.6 million common units representing limited partner interests.
Counseled an MLP in its contribution of a certain terminal pipeline and storage assets for a total consideration of $2 billion.
Represented a downstream oil and gas MLP on the tax aspects of its $1.5 billion merger with an affiliated public corporation.
Guided an upstream oil and gas MLP in its $915 million merger with an affiliated public corporation.

Represented Sanchez Energy Corporation, a publicly owned independent exploration and production company, and certain of its direct and indirect subsidiaries in its chapter 11 cases pending before Judge Marvin Isgur the United States Bankruptcy Court for the Southern District of Texas, with the intention of restructuring approximately $2.3 billion in total funded debt plus significant onerous contractual liabilities.
Represented Franklin Advisors, Inc. in a restructuring involving Chesapeake Energy Corporation. Chesapeake intends to use the proceedings to strengthen its balance sheet and restructure its legacy contractual obligations to achieve a more sustainable capital structure.
Represented AllianceBernstein in its role as pre-petition administrative agent and lender and administrative agent and lender under the post-petition debtor-in-possession (DIP) financing facility in the Chapter 11 bankruptcy cases of Elk Petroleum, Inc. and certain of its affiliates.
Represented Enterprise Products in its $442 million sale to Altus Midstream Company of a 33% equity interest in the Enterprise subsidiary that owns the Shin Oak Pipeline.
Advised Blackstone in connection to Targa Resources Corp. selling a minority stake in its North Dakota oil and gas assets to Blackstone-affiliated funds in a $1.6 billion deal.
Represented a group of consenting creditors in PetroQuest Energy Inc.’s restructuring support agreement with its first lien lenders and second lien noteholders to permanently reduce its debt and the related interest expense in ways that support the long-term growth and success of the business.
Represented AB Holdings LLC in connection with bankrupt oil and gas driller Elk Petroleum Inc. as it progresses through the Chapter 11 process after allowing certain preferred equity holders to convert their holdings to unsecured debt prior to filing its bankruptcy petition.
Advised Viper Energy Partners LP in its underwritten public offering of 10,925,000 common units. The total gross proceeds of the offering (before underwriters’ discounts and commissions and estimated offering expenses) were approximately $340 million.
Represented long-time client Genesis Energy, LP, with respect to a $350 million preferred equity commitment by certain investment fund entities affiliated with GSO Capital Partners in a subsidiary that generates Genesis trona business.
Counseled Diamondback Energy, Inc. on tax matters in connection with several strategic transactions, including its $740 million drop-down sale of certain mineral and royalty interests to Viper Energy Partners LP, $285 million sale of certain conventional and non-core assets in the Permian Basin, $37 million sale of certain non-core assets in the Permian Basin, $1 billion offering of 2.875% senior notes due 2024 and Diamondbacks acquisition of all public common units in Rattler Midstream.
Advised the holdco facility lenders of Salt Creek Midstream, a full service natural gas gatherer and processor on tax matters related to its comprehensive recapitalization, guiding the foreign and domestic lender group through complex U.S. tax issues, and in negotiating and implementing an optimal structure for the debtor companies and the lenders.
Advised Diamondback Energy, Inc. in a joint venture between global alternative asset manager The Carlyle Group L.P. and Diamondback Energy, Inc. to fund the development of Diamondback’s oil and gas assets in the San Pedro area of Pecos County, Texas, within the Southern Delaware basin.
Advised Rattler Midstream LP on tax issues related to its $765 million initial public offering.
Advised Diamondback Energy, Inc. in connection to its definitive purchase agreement to acquire all leasehold interests and related assets of Ajax Resources, LLC for $900 million in cash and 2.58 million shares of Diamondback common stock, subject to certain adjustments.
Represented Rattler Midstream LP in its acquisition of Reliance Gathering, LLC for $355 million in cash, as part of its joint venture entity with Oryx Midstream, a portfolio company of Stonepeak Infrastructure Partners.
Served as tax counsel to Viper Energy Partners LP in converting its federal income tax status from a partnership to a corporation for tax purposes via a “check the box” election.
Counseled Cimarex Energy Co. on the tax aspects of its $1.6 billion cash and stock acquisition of Resolute Energy Corp.
Served as tax counsel to GSO Capital Partners in the formation of, and in its role as a member of, GEP Hayneville LLC, the consortium of GSO and GeoSouthern Haynesville LLC, in the $850 million acquisition of its Haynesville Shale assets from indirect, wholly owned subsidiaries of Encana Corporation.
Provided tax and structuring advice to an ad hoc group of unsecured noteholders of EV Energy Partners, L.P., an independent oil and gas MLP, in its successful financial restructuring and emergence from Chapter 11 as a new corporation under the name Harvest Oil & Gas Corp.
Guided Genesis Energy, L.P. through tax issues related to its
$1.3 billion acquisition of Tronox Ltd.’s alkali business, the world’s largest producer of natural soda ash.
Served as tax counsel to Stone Energy Corporation in its all-stock merger with Talos Energy LLC, a transaction that created Talos Energy, Inc.
Provided tax advice to the conflicts committee of Archrock Partners LP, a natural gas compression services company, in a definitive merger agreement with its parent corporation, Archrock.
Represented 7-Eleven, Inc., the largest chain in the convenience retailing industry, with regard to the tax aspects of its acquisition of more than 100 gasoline and convenience store locations.
Served as tax counsel for EOG Resources, Inc. in its $2.5 billion merger with Yates Petroleum.
Advised Gulfport Energy Corporation on tax issues related to its $1.85 billion acquisition of oil and natural gas assets from Vitruvian II Woodford, LLC.
Provided tax advice to Diamondback Energy, Inc. in its $2.55 billion acquisition of oil and natural gas assets in the Permian Basin from Brigham Resources LLC and in its $560 million acquisition of oil and gas assets in the Southern Delaware Basin.
Advised an MLP client on the tax ramifications of a $142 million public offering of 4.6 million common units representing limited partner interests.
Counseled an MLP in its contribution of a certain terminal pipeline and storage assets for a total consideration of $2 billion.
Represented a downstream oil and gas MLP on the tax aspects of its $1.5 billion merger with an affiliated public corporation.
Guided an upstream oil and gas MLP in its $915 million merger with an affiliated public corporation.

"Her analysis and ability to explain is what makes her unique."

Chambers USA, 2020

Languages
Mandarin
Taiwanese

Education
LL.M., New York University School of Law, 2004
J.D., University of Houston Law Center, cum laude, 2003
B.A., University of Texas at Austin, with honors, 2000

Bar Admissions
Texas

Recognitions

The Legal 500 US, US Taxes: Non-Contentious, 2023-2024.
Chambers USA, Tax, 2017-2024.
Euromoney, Expert Guide, Women in Business Law: Tax, 2022.
Corporate Counsel, Women, Influence & Power in Law: Diversity, Equity and Inclusion Champion, 2022.
The Best Lawyers in America, Tax Law, 2021-2022.
Diversity Journal, Asian Leaders Worth Watching, 2021.
Houston Business Journal, Outstanding Diversity Champion, 2021.
Turnarounds & Workouts, Top Bankruptcy Tax Specialists, 2017-2018 and 2020.
State Bar of Texas, Asian Pacific Interest Section, Champion of Diversity, 2020.
Texas Lawyer, Diversity and Inclusion Champion, 2019.
Houston Business Journal, Women Who Mean Business, 2019.
University of Houston Law Center, Alumni Awards, Private Sector Achievement, 2019.
Texas Lawyer, Lawyer on the Rise, 2017.
Texas Diversity & Leadership Conference, Most Powerful and Influential Women, 2016.
State Bar of Texas, Asian Pacific Interest Section, Best Lawyer Under 40, 2016.
Houston Business Journal, 40 Under 40, 2016.

Affiliations and Public Service

Board of Directors, Asian American Bar Association of Houston.
Member, Houston Bar Association Tax Section.
Member, Texas Bar Association Tax Section.
Member, State Bar of Texas Asian Pacific Interest Section.

Speeches and Publications

“Business Update for Owners: Legal, Tax and Market Update,” XPX Owners’ Academy, Houston, April 2024.
“5 Strategies for Building Your Internal Brand,” 2022 Corporate Counsel Women of Color Conference, Atlanta, October 2022.
“Investing and Financing in the Oil and Gas Industry,” 15th Biennial Parker C. Fielder Oil and Gas Tax Conference, Houston, November 2019.
“Selected Tax Issues Involving Special Purpose Acquisition Vehicles (SPACs) and Recent Deals in the Energy Space,” Houston Tax Roundtable, Houston, May 2019.
“Impact of Tax Reform on the Energy Sector: A Lively Discussion of Major Changes Affecting Energy Companies and Power Projects,” Akin Energy Briefing, Houston, January 2018.
"The New Energy Paradigm: Investing and Operating in the Current Market,” Akin Energy Briefing, Houston, January 2018.
“MLP Matters: New IRS Guidance,” Akin Mid-Year Energy Briefing, Houston, July 2015.