Photo of Peter A. Lowy

Peter A. Lowy

Shareholder

Education

LL.M., New York University School of Law, 1997

J.D., Tulane University Law School, 1995, cum laude, member of Tulane Law Review

B.A., Hobart and William Smith Colleges, 1992, with honors

Honors

Recipient, Pro Bono Award from the American Bar Association Section on Taxation, 2003

Recipient, Nolan Fellowship from the American Bar Association Section on Taxation, 2007

Bar Admissions

New York (1996)

Texas (2003)

District of Columbia (2014)

Court Admissions

U.S. Supreme Court

U.S. Court of Appeals for the Second Circuit

U.S. Court of Appeals for the Fifth Circuit

U.S. Court of Appeals for the Federal Circuit

U.S. Tax Court

U.S. District Court for the Southern District of New York

U.S. District Court for the Southern District of Texas

U.S. Court of Federal Claims

Clerkships

Judicial Clerk, The Honorable Nauman Scott, U.S. District Court, Western District of Louisiana, 1995-1996

Attorney Advisor, The Honorable Maurice Foley, U.S. Tax Court, Washington, D.C., 1997-1998

Profile

Pete Lowy, a nationally-recognized attorney, joined Chamberlain Hrdlicka in 2015 as a Shareholder in the firm's Houston office. He is best known for his tax controversy work and deep experience in the energy sector but also advises corporations and other taxpayers in a broad range of industries on tax compliance issues, tax planning, and risk management, in addition to handling high-stakes Federal and State tax audits and litigation.

Mr. Lowy is the current chair of the American Bar Association Tax Section’s Energy Tax Committee, and is the immediate-past chair of its Committee on Court Procedure & Practice. He is an adjunct law professor at the University of Houston Law Center where he teaches Tax Controversies & Litigation, and is widely published on tax audits and litigation-related subjects. Prior to entering private practice, he worked in-house for Exxon Mobil Corporation, and then for Royal Dutch Shell, where he held an executive position with worldwide management responsibilities for Shell's tax litigation.

During his career, Mr. Lowy has handled over 100 tax cases that involved billions of dollars in taxes and that have cut across many types of taxes, including federal income and excise taxes, as well as state and/or local sales & use taxes, motor fuels taxes, property taxes, severance taxes, income taxes, and franchise taxes including the Texas margins tax. He has also advised on structuring multi-billion dollar cross-border transactions; conducted internal investigations; provided tax opinions on return positions; and obtained rulings including Private Letter Rulings from the IRS and State tax authorities. Mr. Lowy regularly works with the IRS and the Texas Comptroller’s office.

Dedicated throughout his career to pro bono work, Mr. Lowy devotes substantial time each year to representing underprivileged taxpayers. A leader in the pro bono field, Mr. Lowy is a past chair of the ABA Tax Section's Pro Bono Committee and coordinates a pro bono program to assist unrepresented taxpayers in litigation at the U.S. Tax Court. In 2003, his work with disadvantaged taxpayers earned him the ABA Tax Section's Pro Bono Award, and in 2014 he received the “Access to Justice” pro bono service award from the New York State Courts.

Mr. Lowy earned his LLM in Taxation from New York University School of Law, and his JD from Tulane Law School. Following law school, he clerked for a United States District Court and served as an attorney-advisor to the United States Tax Court.

Recent Speaking Engagements

  • Speaker, Preparing for Partnership Tax Audits, University of Houston Tax Procedure Seminar, September 8, 2016
  • Speaker, Crash Course in Texas Taxes, Chamberlain Tax Forum, May 25, 2016

  • Speaker, State & Local Taxes: A View from the Trenches, Wednesday Tax Forum, May 10, 2016

  • Panelist, Strategies for Closing Open Years: Audit and Litigation, Tax Executive Institute Roundtable, June 18, 2015
  • Panelist, Cross Border Attorney - Client Priviledge Issues, American Bar Association, Tax Section Meeting, May 8, 2015
  • Panelist, Transfer Pricing Update, American Petroleum Institute 81st Federal Tax Forum, April, 28, 2015
  • Chair, Energy & Environmental Taxes, American Bar Association, 2015 Midyear Meeting, January 30, 2015
  • Panelist, Cross Border Tax Issues in Oil & Gas, Texas Federal Tax Institute, Oil & Gas Tax Conference, November 3, 2014
  • Chair, Energy & Environmental Taxes Committee, American Bar Association, 2014 Joint Fall CLE Meeting, September 19, 2014
  • Panelist, U.S. State Tax Considerations for International Tax Reform, Tax Analysts, June 18, 2014
  • Speaker, Global Tax Planning & Audit Defense Strategies in the Changing World of Intangibles, Tax Executive Institute, May 9, 2014
  • Chair, Energy and Environmental Taxes, American Bar Association, 2014 May Meeting, May 9, 2014
  • Moderator, Litigating Cross-Border Transactions in U.S. Courts, American Bar Association, May 9, 2014
  • Speaker, OECD BEPS Update, 80th Annual API Federal Tax Forum, April 28, 2014
  • Moderator, Hot Topics In the Energy Industry, American Bar Association, January 24, 2014
  • Speaker, Transfer Pricing in the Oil and Gas Industry: Exploring Key Issues from Concept through Implementation, 12th Biennial Parker C. Fielder Oil and Gas Tax Conference, November 21, 2013
  • Moderator, Transfer Pricing in the Oil and Gas Industry: Exploring Key Issues from Concept through Implementation, 12th Biennial Parker Fielder Oil & Gas Tax Conference, November 21, 2013
  • Speaker, Hot Topics in Tax Enforcement, 24th Annual Philadelphia Tax Conference, November 6, 2013
  • Speaker, From the Experts: Tax Controversy and Tax Litigation Update, 72nd Institute on Federal Taxation, October 20, 2013
  • Speaker, Managing Risk in a New Era of International Tax Enforcement, Tax Executive Institute, Houston Chapter, Monthly Luncheon, October 17, 2013
  • Moderator, Competent Authority: What Happens When More Than One State Wants to
  • Tax the Same Income or Transaction?, California Tax Policy Conference, November 4, 2011
  • Moderator, Comparing U.S. & Canada Approaches to Unrepresented Taxpayer Issues, American Bar Association, September 23, 2010
  • Moderator, Strategies for Resolving International Tax Disputes, International Tax Forum, September 1, 2010
  • Moderator, Transfer Pricing Litigation, American Bar Association, January 21, 2010
  • Moderator, Getting to Yes – Dealing with IRS Cradle to Grave, 10th Biennial Parker Fielder Oil & Gas Tax Conference, October 29, 2009
  • Moderator, Settling Tax Cases, American Bar Association, May 9, 2008

Professional Affiliations

  • Adjunct Professor, University of Houston Law Center, 2000, 2005-present (Legal Research & Writing, 2000; Tax Research, 2005-2013; Tax Controversies 2008-2013, 2016-present)
  • Adjunct Professor - Tax Controversies, Texas Southern University Law School, 2011
  • Chair, Court Procedure and Practice Committee, American Bar Association Section on Taxation, 2011-2013
  • Chair, Pro Bono Committee, American Bar Association Section on Taxation, 2009-2011
  • Chair, Energy & Environmental Taxes Committee, American Bar Association Tax Section, 2013-present
  • Council, American Bar Association Presidential Task Force on Attorney-Client Privilege, 2005-2010
  • Council, Houston Bar Association Section on Taxation, 2005-2013
  • Lead/Coordinator, Tax Court Calendar Call Program, Houston, 2010-2013, 2016-present
  • Member, Appointments to the Tax Court Committee, American Bar Association Section on Taxation, 2013-present
  • Member, American College of Tax Counsel, 2016-present

Publications

Articles & Publications

  • U.S. Federal Tax Research, 2nd Ed., TAX MANAGEMENT PORTFOLIO SERIES (2014).
  • Responsible Person and Lender Liability for Trust Fund Taxes - Sections 6672 and 3505, TAX MANAGEMENT PORTFOLIO SERIES (2010) (co-author) (new edition commissioned for 2016).
  • Effectively Representing Your Client Before the IRS, 5th Edition, American Bar Association Tax Section (2011) (contributing editor).