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; member of Tulane Law Review

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

Honors

Nolan Fellowship, American Bar Association, Section on Taxation, 2007

Pro Bono Award, American Bar Association, Section on Taxation, 2003

Bar Admissions

Texas (since 2003)

New York (since 1996)

District of Columbia (since 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

Peter A. Lowy, a shareholder in Chamberlain Hrdlicka’s Houston office, is best known for his tax controversy work and deep experience in the energy sector. He also advises corporations and other taxpayers in a broad spectrum of industries on tax compliance issues, tax planning, and risk management. He regularly works with the Internal Revenue Service and the Texas Comptroller’s office on a wide range of matters.

During his career, Mr. Lowy has been responsible for over 100 tax cases that have cut across many types of taxes, including U.S. federal income, excise & employment taxes; state direct taxes (e.g., income and franchise taxes); state and local indirect taxes (e.g., sales & use, motor fuels, and other specialty taxes); and state and local ad valorem taxes (e.g., property and severance taxes). Disputes Mr. Lowy has participated in include ten cases with amounts in issue exceeding $100 million each, and two cases that exceeded $1 billion in issue. He also served as lead attorney in structuring several transactions including a multi-billion dollar, cross-border deal in the energy sector.

Dedicated throughout his career to pro bono work, Mr. Lowy devotes substantial time each year to represent 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 for the U.S. Tax Court. In 2003, his work with disadvantaged taxpayers earned him the ABA Tax Section's Pro Bono Award. In 2015, his  pro bono work earned him the Access to Justice Award from the New York State Courts.

Mr. Lowy is the current chair of the American Bar Association Tax Section’s Energy Tax Committee, and is the former chair of the American Bar Association Tax Section's Committee on Court Procedure & Practice. Mr. Lowy has been an adjunct law professor at two law schools where he taught Tax Controversies, and is widely published on tax audits and litigation-related subjects.

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 the United States District Court and for the United States Tax Court.

Selected Speaking Engagements

  • Speaker, Crash Course in Texas Taxes, Chamberlain Hrdlicka Tax Forum, November 3, 2016
  • Panelist, Strategies for Closing Open Years: Audit and Litigation, Tax Executive Institute Roundtable, June 18, 2015
  • Panelist, Cross Border Attorney - Client Privilege 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, Tax Section 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, Tax Section 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, Tax Section Meeting, May 9, 2014
  • Moderator, Litigating Cross-Border Transactions in U.S. Courts, American Bar Association, Tax Section Meeting, May 9, 2014
  • Speaker, OECD BEPS Update, American Petroleum Institute 80th Federal Tax Forum, April 28, 2014
  • Moderator, Hot Topics In the Energy Industry, American Bar Association, Tax Section MeetingJanuary 24, 2014
  • 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 NYU 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, Tax Section Meeting, September 23, 2010
  • Moderator, Strategies for Resolving International Tax Disputes, International Tax Forum, September 1, 2010
  • Moderator, Transfer Pricing Litigation, American Bar Association, Tax Section Meeting, 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, Tax Section Meeting, May 9, 2008

Selected 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 forthcoming)
  • Effectively Representing Your Client Before the IRS, 5th Edition, American Bar Association Tax Section (2011) (contributing editor)

Professional Affiliations

  • Adjunct Professor, University of Houston Law Center (2000, 2005-2013)
  • Adjunct Professor, University of Houston Law Center -Legal Research & Writing (2000)
  • Adjunct Professor, University of Houston Law Center - Tax Research (2005-2013)
  • Adjunct Professor, University of Houston Law Center - Tax Controversies (2008-2013, 2016-present)
  • Adjunct Professor, Texas Southern University Law School - Tax Controversies (2011)
  • Chair, Court Procedure & Practice, American Bar Association Section on Taxation (2011-2013)
  • Chair, Pro Bono Committee, American Bar Association Section on Taxation (2009-2011)
  • Chair, Energy & Environmental Taxes, American Bar Association Section on Taxation (2013-present)
  • Council, American Bar Association Presidential Task Force On Attorney-Client Privilege (2005-2010)
  • Council, Houston Bar Association Section on Taxation (2005-2013)
  • 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)
  • Recipient, Access to Justice Pro Bono Award, New York State Courts (2015)
  • Lead/Coordinator, Tax Court Calendar Call Program in Houston (2010-2013, 2016-present)
  • Member, American College of Tax Counsel (2016-present)