Nelson Mullins partners Mauricio Rivero, Jim Reardon, and Henry “Buzz” Burwell, with contributions from partner John Haley, authored an article for Bloomberg Tax, "US Sanctions Crack Open Door for Energy Investment in Venezuela,” discussing how to navigate Venezuela’s legally complex energy market.

“Venezuela holds the world’s largest proven oil reserves, yet decades of sanctions, mismanagement, and political instability have left its production infrastructure severely underdeveloped,” they advised. “That is now changing, at least at the policy level.”

They further explained the different policies and tax issues multinationals need to weigh.

“In general, US investors are allowed a foreign tax credit for income taxes paid to Venezuela,” they said. “However, the credit is generally limited to the amount of US tax attributable to the foreign-source income, calculated separately for different categories of income (such as general, passive, and oil and gas income). The treaty’s relief is thus subject to the same foreign tax credit limitations.”

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