Steven D. Moore
Practice Areas
Experience
- Aircraft Ownership, Operation, & Transactions
- Data Center
- Family Office
- International Taxation
- Public-Private Partnerships
- Renewable Energy
- South Korea
- State & Local Tax
- Tax Controversy & Litigation
- Tax Exempt & State Non-Profit
Biography
Recognized for his depth of expertise in Texas sales tax, franchise (aka “margin”) 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 in Texas State Bar and University of Texas CLE programs. Steve is dedicated to helping his clients fully comply with and limit state tax exposure.
Steve Moore’s state tax practice includes (i) Wayfair structuring, planning, and compliance, (ii) sales tax, (iii) Texas franchise (aka “margin”) tax, (iv) property (ad valorem) tax including Chapter 312, 380, and 381 property tax abatements; (v) Chapter 313 (now expired) property tax value limitation agreements, (vi) Chapter 351 qualified hotel projects; and (vii) insurance premium tax and insurance retaliatory tax. He has industry leading experience with the state tax issues affecting the renewable energy industry in Texas.
Current practice initiatives include leveraging industry and school district relationships to encourage application of the Jobs Energy Technology & Innovation Act (the “JETI” Act) in Chapter 403 of the Texas Government Code from House Bill 5 in the 2023 Texas Legislature as well as pursuing applications under the Texas CHIPS Act from House Bill 5174 in the 2023 Texas Legislature.
Steve advises multi-state businesses, and regularly provides tax strategy advice related to business mergers, acquisitions, and divestitures. Economic nexus or factor presence nexus planning and exposure mitigation is critical in merger and acquisition work from both the buyer’s and seller’s perspective. An effective negotiator, Steve works to reach successful resolutions to Texas sales, franchise, property, and insurance premium tax audits. To this end, Steve and his Jackson Walker state and local tax colleague, Alison Andrews, work to resolve audits and conduct administrative hearings before the Texas State Office of Administrative Hearings and prosecute judicial appeals of Texas state 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
- Represented multinational semiconductor chip manufacturer in successful negotiations of local property tax incentives in support of multibillion dollar FAB development.
- Represented developers of utility-scale solar and wind power projects in connection with negotiations for state and local property tax incentives (Chapter 313 (now sunset) and Chapter 312, 380, and 381) on their projects in counties across Texas.
- Established Large Data Center status with the Texas Comptroller of Public Accounts for two large (> $500 million) data center projects.
- Represented lenders and investors for local counsel state tax diligence purposes on scores of wind and solar projects in Texas.
- Represented a major solar and wind developer in a successful Texas franchise tax protest and establishment of an exemption under Section 171.056.
- 2018, 2019, 2020, 2021, 2022, and 2023 successful negotiations of valuable tax abatement agreements in major metropolitan cities and counties for Fortune 100 technology clients, transportation clients, and clients’ utility scale solar developments, windfarms, data center developments, and expansions representing several billion dollars in new Texas investments.
- SALT work in large business acquisitions and sales to navigate (i) Texas franchise tax results, (ii) preservation of state and local incentives, (iii) traditional and economic nexus diligence post-Wayfair, (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 (now expired) value limitation 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.
- 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.
- 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.
- Chambers USA: America’s Leading Lawyers for Business, Ranked for Tax: State & Local – Texas (Band 1), 2025
- The Best Lawyers in America (Woodward/White Inc.), 2015-2025
- Lawyer of the Year – Austin, Litigation and Controversy – Tax, 2024
- Insurance Law, 2015-2025
- Litigation and Controversy – Tax, 2021-2025
- Tax Law, 2020-2025
- Texas Super Lawyer, Super Lawyers by Thomson Reuters, 2021-2022
- “Austin’s Top Attorneys” List – Tax Law, Austin Monthly, 2023
- Texas Rising Star, Super Lawyers – Rising Stars by Thomson Reuters, 2004
Publications
SALT Issues in Merger and Acquisition Transactions co-authored with Willie Hornberger 2023 Texas Society of CPAs Summit Conference.
Multistate SALT Issues and Business Migration co-authored with Christi Mondrik, November 2022 for University of Texas CLE Taxation Conference
SALT Considerations In Merger and Acquisition Diligence November 2022, Presented to the Dallas Bar Association Tax Section
The State Tax Law Landscape – Wayfair and Beyond May 2021, Co-Authored with Christi Mondrik and Ray Langenberg
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
- Member of the Texas Taxpayer and Research Association (TTARA)
- KMFA FM 89.5
- Board of Trustees
- Chairman of the Board, 2005 – 2013; Dear Music Capital Campaign Co-Chair, 2017-2021
- STEM-focused Austin Technology Council Community Foundation, Board Member, 2011 – 2016
- Bloomberg BNA’s Texas Corporate Income Tax Portfolio and Navigator, Texas Editor, 2017
June 5, 2025
Spotlight
Chambers and Partners Releases 2025 USA Guide Featuring 79 Jackson Walker Attorneys and 28 Ranked Departments
Jackson Walker is pleased to announce that Chambers and Partners has selected 79 attorneys and 28 departments for inclusion in the 2025 edition of the Global and USA guides. Attorneys were ranked across 29 departments, with 4 attorneys listed among multiple areas, 9 ranked nationwide in their respective areas, and 12 recognized for the first time.
June 5, 2025
Spotlight
Jackson Walker Ranked for Tax: State & Local in Chambers USA Guide
Jackson Walker is proud to announce that its State & Local Tax practice has been ranked for the first time in the 2025 Chambers USA Guide released today. In addition, partner Steven Moore and associate Ashley Withers were individually recognized.
August 15, 2024
Attorney News
‘The Best Lawyers in America’ Features 306 Jackson Walker Attorneys in 2025 Edition, Including 9 “Lawyers of the Year” and 75 “Ones to Watch”
The Best Lawyers in America has recognized 306 Jackson Walker attorneys across 81 specialty practice areas in its 2025 edition, including 9 Lawyers of the Year and 75 Ones to Watch. In this year’s guide, Jackson Walker saw the largest number of attorneys in the areas of Commercial Litigation (75 attorneys) and Real Estate Law (55 attorneys) and the addition of 27 attorneys as Best Lawyers.
July 11, 2024
Attorney News
‘Austin Monthly’ Lists 21 Jackson Walker Attorneys Among “Austin’s Top Attorneys” of 2024
Jackson Walker congratulates the 21 attorneys recognized among Austin Monthly’s list of “Austin’s Top Attorneys” for 2024. For recognition in the list, Austin attorneys must be nominated by their peers on the basis that they offer experienced counsel in one of 39 categories.
August 17, 2023
Attorney News
‘The Best Lawyers in America’ Honors 287 Jackson Walker Attorneys in 2024 Edition, Including 12 “Lawyers of the Year” and 80 “Ones to Watch”
The Best Lawyers in America has recognized 287 Jackson Walker attorneys across 5 offices and 82 specialty practice areas in its 2024 edition, including 12 Lawyers of the Year and 80 Ones to Watch. In this year’s guide, Jackson Walker saw the largest number of attorneys in the areas of Commercial Litigation (66 attorneys) and Real Estate Law (60 attorneys) and the addition of 35 attorneys as Best Lawyers.
July 17, 2023
Attorney News
‘Austin Monthly’ Lists 12 Jackson Walker Attorneys Among “Austin’s Top Attorneys” of 2023
Jackson Walker congratulates the 12 attorneys recognized among Austin Monthly’s list of “Austin’s Top Attorneys” for 2023. For recognition in the list, Austin attorneys must be nominated by their peers on the basis that they offer experienced counsel in one of 39 categories.
September 21, 2022
Attorney News
Jackson Walker Congratulates Its 64 “Texas Super Lawyers” of 2022
Each year, less than 5% of attorneys in Texas are named to the list. Selection is based off of peer nominations that are then reviewed by a research team. Each nominee is evaluated on his or her professional accomplishments, peer recognition, and community involvement.
August 18, 2022
Attorney News
‘The Best Lawyers in America’ Honors 214 Jackson Walker Attorneys in 2023 Edition, Including 11 “Lawyers of the Year” and 41 “Ones to Watch”
The Best Lawyers in America has recognized 214 Jackson Walker attorneys across 6 offices and 79 specialty practice areas in its 2023 edition, including 11 Lawyers of the Year and 41 Ones to Watch. Best Lawyers listings are based on an exhaustive peer review survey of thousands of attorneys who vote on the legal abilities of others in their practice areas.
Practice Experience
- Represented multinational semiconductor chip manufacturer in successful negotiations of local property tax incentives in support of multibillion dollar FAB development.
- Represented developers of utility-scale solar and wind power projects in connection with negotiations for state and local property tax incentives (Chapter 313 (now sunset) and Chapter 312, 380, and 381) on their projects in counties across Texas.
- Established Large Data Center status with the Texas Comptroller of Public Accounts for two large (> $500 million) data center projects.
- Represented lenders and investors for local counsel state tax diligence purposes on scores of wind and solar projects in Texas.
- Represented a major solar and wind developer in a successful Texas franchise tax protest and establishment of an exemption under Section 171.056.
- 2018, 2019, 2020, 2021, 2022, and 2023 successful negotiations of valuable tax abatement agreements in major metropolitan cities and counties for Fortune 100 technology clients, transportation clients, and clients’ utility scale solar developments, windfarms, data center developments, and expansions representing several billion dollars in new Texas investments.
- SALT work in large business acquisitions and sales to navigate (i) Texas franchise tax results, (ii) preservation of state and local incentives, (iii) traditional and economic nexus diligence post-Wayfair, (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 (now expired) value limitation 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.
- 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.
- 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.
Recognition & Accolades
- Chambers USA: America’s Leading Lawyers for Business, Ranked for Tax: State & Local – Texas (Band 1), 2025
- The Best Lawyers in America (Woodward/White Inc.), 2015-2025
- Lawyer of the Year – Austin, Litigation and Controversy – Tax, 2024
- Insurance Law, 2015-2025
- Litigation and Controversy – Tax, 2021-2025
- Tax Law, 2020-2025
- Texas Super Lawyer, Super Lawyers by Thomson Reuters, 2021-2022
- “Austin’s Top Attorneys” List – Tax Law, Austin Monthly, 2023
- Texas Rising Star, Super Lawyers – Rising Stars by Thomson Reuters, 2004
Publications & Speeches
Publications
SALT Issues in Merger and Acquisition Transactions co-authored with Willie Hornberger 2023 Texas Society of CPAs Summit Conference.
Multistate SALT Issues and Business Migration co-authored with Christi Mondrik, November 2022 for University of Texas CLE Taxation Conference
SALT Considerations In Merger and Acquisition Diligence November 2022, Presented to the Dallas Bar Association Tax Section
The State Tax Law Landscape – Wayfair and Beyond May 2021, Co-Authored with Christi Mondrik and Ray Langenberg
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
Community Involvement
- Member of the Texas Taxpayer and Research Association (TTARA)
- KMFA FM 89.5
- Board of Trustees
- Chairman of the Board, 2005 – 2013; Dear Music Capital Campaign Co-Chair, 2017-2021
- STEM-focused Austin Technology Council Community Foundation, Board Member, 2011 – 2016
- Bloomberg BNA’s Texas Corporate Income Tax Portfolio and Navigator, Texas Editor, 2017