Attachment 2 - Proforma IDRs for EOR Tax Credit
Attachment 2
Proforma IDRs for EOR Tax Credit
First IDR
• Request a schedule of the qualified costs and credit claimed on Form
8830 by project. For each project the total amount of qualified costs
should be listed along with the subtotals of IDC, tangible equipment,
and tertiary injectant expense.• Request verification that the amount of credit reported on Form 8830
during the tax year has reduced the taxpayer’s basis and/or expense
deduction of the underlying cost in accordance with IRC section
43(d).
Second IDR
For those projects that are material in size and where there is little if any audit history, you should request the following for each –
• Copy of any and all Petroleum Engineer’s Certifications including, but not
limited to the original project certification and any revised or superseded
project certification• Operator’s continued Certification for the years of the examination
Third IDR
Once you have determined that certain projects should be looked into more closely, issue an IDR asking for the following on each project –
• The identity of the operator, and if your taxpayer is the operator, a list of all
the working interest owners• Unless contained in the Petroleum Engineer’s certification, a map large
enough to determine the type of well, the name of the well, and the location
of each project area. The map should reflect the status of the wells as
related to the audit year(s).• Of the total amount claimed as tertiary injectant costs, a breakdown
between the cost attributable to purchases of the injectant from third
parties, and the cost attributable to other than such purchases (such as
recycling costs)• Supporting details for the volume of all tertiary injectants that were
injected into the project’s reservoir during the taxable year. The
details should include the break down between purchased injectant
and recycled injectant.• A list of all wells used in the implementation or operation of the project
regardless of spud date. If possible this list should be as of the effective
date of the certification and reflect any changes for subsequent years.
This list should include or indicate the following:o Whether each well is a producer, injector or other during
the audit year(s)
o Spud date for each well
o Completion interval(s) for each well and an indication of
whether the well is completed in more than one reservoir• For the amount claimed as intangible drilling costs (IDC), a list of the wells
including an indication of their type (e.g. producer, injector) and the cost of
each• For the amount claimed as tangible equipment, a descriptive list of the
equipment, the cost of each item, and placed-in-service date.Additional IDRs based upon issue development
IDR for Significant Expansion Issue:
• If the Petroleum Engineer’s certification is not clear, request an
explanation of the delineation between the pre-1991 project and the
post-1990 significant expansion project.• If the Petroleum Engineer’s certification is not clear, request an
explanation of the determination that the expansion project will
increase the ultimate recovery f crude oil over that expected from the
continuation of the previously implemented project.• Request an explanation of the methodology used to determine what
costs were incurred with respect to the expansion project versus those
incurred for other purposes including the pre-1991 project.
IDR for Qualified Costs in General:
Request an explanation of the methodology used to determine what costs were incurred with respect to the project versus those incurred for other purposes, and whether they were incurred for the primary purpose of implementing one or more EOR projects.
• Request the names of the individuals including their title who
determined the methodology used to determine the “Qualified Costs”
in the subject EOR project.
IDR for Tertiary Injectant Cost Issue:
For each project being reviewed:
• Request a copy of the supporting details and documents that show how the
qualified tertiary injection costs were determined• Request a table that indicates volume and type of each substance
injected by well during the year. This table should be in machine
sensible format. Are these volumes the same as those reported to the
State / Federal regulatory agency? If not, why not?• Request explanation of the methodology used to determine tertiary injectant
costs other than the cost to acquire injectants by purchase• Request a process flow diagram of surface operations
• Request a copy of the lease operating statements for the years under
examination• Request a list of documents that discuss either the operations of the
project or the operations of the oil field where the project is located.
Examples include internal engineering or operations studies, SPE
papers, and the minutes of working interest owners’ meetings.
