Biography
Recognized for his depth of expertise in Texas sales tax, franchise tax, and property tax matters, Steve is one of the state’s leading attorneys for guidance on the Texas margin tax and Texas sales tax and he frequently speaks on these topics, with ongoing commitments for presentations to Texas State Bar and University of Texas CLE programs.
Steve Moore’s state tax practice includes planning and controversy work on (i) sales tax, (ii) Texas franchise (aka “margin”) tax, (iii) property (ad valorem) tax including Chapter 312, 380, and 381 property tax abatements; (iv) Chapter 313 property tax value limitation agreements, and (v) insurance premium and retaliatory tax. Steve is dedicated, from a value-driven perspective, to helping his clients fully comply with and control state tax exposure.
Steve advises multi-state businesses, and regularly provides tax strategy advice relating to business mergers, acquisitions, and divestitures. An effective negotiator, Steve works to reach successful and economically viable resolutions to Texas sales, franchise, property, motor vehicle, and insurance premium tax audits. To this end, he handles administrative hearings before the Texas Comptroller of Public Accounts and works with the firm’s litigation group to prosecute judicial resolution of Texas tax cases.
Education
B.B.A., with high honors, University of Texas at Austin
J.D., with honors, University of Texas School of Law
- Order of the Coif, Top 10%
Bar Admissions
Texas, 1989
- 2017 and 2018 successful negotiations of valuable tax abatement agreements in major metropolitan cities and counties for Fortune 100 and other clients’ green field developments and expansions representing several billion dollars in new Texas investments and related P3 considerations.
- SALT work in large business acquisitions and sales to navigate (i) Texas franchise tax results, (ii) preservation of state and local incentives, (iii) nexus concerns, (iv) transfer taxes, (v) occasional sale exemptions, and (vi) successor liability.
- Energy project acquisition and development advice to maximize benefits from state and local tax incentives including Chapter 312 and Chapter 313 abatement work as well as qualifications for sales tax exemptions available to data centers and large data centers.
- Ongoing representation of major investors, lenders, and developers of billions of dollars on Texas renewable energy projects as lead and local counsel and provide due diligence on state sales tax compliance and state and local tax incentives and other aspects of such projects.
- 2015 successful audit defense of retaliatory tax assessment against non-Texas life insurer resulting in allowance of foreign state’s investment credits.
- Numerous aircraft acquisitions, sales, and ongoing operations modeled to achieve best-available state sales, use, and property tax treatment under Chapter 163 of the Texas Tax Code adopted in 2015.
- Planning and compliance with respect to Texas sales tax on services, including bundled “data processing” transactions.
- Non-lobby monitoring and advising on pending and proposed Texas tax legislation and policy.
- Travis County District Court victory establishing renewable energy construction company’s right to Texas franchise tax exemption under Section 171.056 of the Texas Tax Code.
- The Best Lawyers in America (Woodward/White Inc.)
- Insurance Law, 2015-2021
- Tax Law, 2020-2021
- Litigation and Controversy – Tax, 2021
- Member of the Texas Taxpayer and Research Association (TTARA)
Steve’s article “Nexus and State Tax Due Diligence” was published in the Summer 2012 edition of Texas Journal of Business Law. He has made numerous speaking presentations to major CLE programs across Texas dealing with various state tax and corporate topics, including “The New Texas Margin Tax.”
Steve joined his Jackson Walker colleagues William Hornberger and Byron Egan as a contributor in the article “Robust Economic Growth and Tax Law Changes Mean Choice of Entity Decisions More Important than Ever,” published in The Texas Lawbook in April 2019.
Speeches
Business Aspects of Combined Reporting
Acquisitions and Dispositions of Oil and Gas Assets
Texas Aviation Sales and Use Tax Issues
A Margin Tax Update
Acquisitions, Dispositions and Reorganizations
From Oil Patch to Fund – State Tax Due Diligence
Choice & Acquisition of Entities in Texas
Aircraft Transaction Basics: A Business Development Opportunity
Legislative Update; Business Law Webcast
Choice & Acquisition of Entities in Texas
State Tax Legislative Update
Texas Margin Tax Update
Basic Nuts and Bolts Planning Techniques with Texas Franchise Tax
- KMFA FM 89.5
- Board of Trustees
- Chairman of the Board, 2005 – 2013
- STEM-focused Austin Technology Council Community Foundation, Board Member, 2011 – 2016
- Bloomberg BNA’s Texas Corporate Income Tax Portfolio and Navigator, Texas Editor, 2017