Maggie Caldwell

Industry Sectors

• Upstream
• Midstream
• Downstream
• Power, Utilities & Renewables
• Private Equity

Principle Areas of Practice

• Tax Compliance & Provision
• Federal & State Income Tax Planning
• Mergers, Acquisitions & Divestitures
• Tax Structuring & Optimization
• ASC 740 Tax Provisions
• Bankruptcy Tax Attribute Optimization
• Transactional Support

Professional Experience

Maggie Caldwell is a Managing Director in Opportune LLP’s Tax Advisory practice. With over eleven years of federal tax and accounting experience, Maggie specializes in providing tax compliance and provision advisory services across various sectors of the energy industry. Her expertise extends to complex transactions, including mergers and acquisitions, IPOs, and bankruptcy-related tax optimization. She has a deep expertise in partnership taxation and treatment of Intangible Drilling Costs and a strong background in navigating Subchapter K of the Internal Revenue Code.

Before joining Opportune, Maggie worked at PricewaterhouseCoopers LLP (PwC), where she focused on tax compliance and auditing income tax provisions for SEC registrants. At Opportune, she has provided tax compliance and consulting services to investors across numerous segments of the energy and natural resources industry. She specializes in structuring tax-efficient entities, analyzing partnership agreements, creating models for HLBV and various tax credits, and navigating the income tax implications of complex mergers and acquisitions, UP-C transactions, IPOs, and bankruptcy tax attribute optimization, as well as overall case administration. She has also served as an expert witness in oil and gas disputes.

Representative Projects

• Structured complex oil & gas partnership agreements to ensure proper allocation of IDCs, depletion, and other tax attributes in compliance with Subchapter K, including special allocations under §704(b) and §704(c). Helped sponsors and investors achieve alignment on economic and tax objectives through strategic modeling.
• Assisted high-net-worth individual investors in navigating passive activity loss (PAL) limitations under IRC §469, particularly in the context of oil & gas investments. Developed tailored strategies for passive loss exemptions and grouping elections to minimize suspended and passive losses and maximize current-year deductions.
• Consulted on exit planning and basis management for partners in resource partnerships, including tracking of outside basis, gain recognition upon disposition, and impact of suspended losses. Ensured proper treatment of IDCs and other deductions in final year allocations and liquidation events.
• Reviews and signs over 300 federal and state income tax returns annually for individuals, corporations, partnerships, non-profit organizations, and regulated investment companies majority of which are in the energy and natural resource industry.
• Implements creative structuring solutions for tax efficiency.
• Creates HLBV Models for complex entity structures in order to calculate required distributions and tax distributions for investors
• Served as a de facto controller for a high-profile company during bankruptcy, successfully completing a federal income tax audit with a “no change” outcome for multiple periods.
• Successfully resolved Bankruptcy tax claims in over 40 jurisdictions.
• Led a successful Texas Margin Tax audit, defending Intangible Drilling Costs (IDCs) inclusion despite scrutiny from the Texas Comptroller’s office.
• Secured a $7 million refund for a client following an IRS challenge.
• Provides tax advice and related calculations for a variety of transactions including; disguised sale analysis, reverse subsidiary mergers, UP-C structures and Sections 382 and 280G analysis.