Steven Moore

Practice Areas

Aircraft Ownership, Operation, & Transactions • Data Center • Family Office • International Taxation • Public-Private Partnerships • Renewable Energy • State & Local Tax • Tax Controversy & Litigation • Tax Exempt & State Non-Profit

Career

Steve Moore leads Jackson Walker’s State & Local Tax (SALT) practice, bringing decades of experience advising businesses on Texas sales tax, franchise (margin) tax, and property tax matters. Known for his deep knowledge of Texas tax law, Steve regularly advises on state tax strategy, compliance, and controversy, including audit defense and litigation. He has significant experience with data centers, renewable energy taxation, economic development incentives, and legislative programs.

Professional Memberships

Texas Taxpayer and Research Association (TTARA)

KMFA FM 89.5, Past Board of Trustees

STEM-focused Austin Technology Council Community Foundation, Past Board Member

Bloomberg BNA’s Texas Corporate Income Tax Portfolio and Navigator, Texas Editor, 2017

Work Highlights

- Represented multinational semiconductor chip manufacturer in successful negotiations of local property tax incentives in support of multibillion dollar FAB development.

- Represented developers of utility-scale solar and wind power projects in connection with negotiations for state and local property tax incentives (Chapter 313 (now sunset) and Chapter 312, 380, and 381) on their projects in counties across Texas.

- Established Large Data Center status with the Texas Comptroller of Public Accounts for two large (> $500 million) data center projects.

- Represented lenders and investors for local counsel state tax diligence purposes on scores of wind and solar projects in Texas.

- Represented a major solar and wind developer in a successful Texas franchise tax protest and establishment of an exemption under Section 171.056.

- 2018, 2019, 2020, 2021, 2022, and 2023 successful negotiations of valuable tax abatement agreements in major metropolitan cities and counties for Fortune 100 technology clients, transportation clients, and clients’ utility scale solar developments, windfarms, data center developments, and expansions representing several billion dollars in new Texas investments.

- SALT work in large business acquisitions and sales to navigate (i) Texas franchise tax results, (ii) preservation of state and local incentives, (iii) traditional and economic nexus diligence post-Wayfair, (iv) transfer taxes, (v) occasional sale exemptions, and (vi) successor liability.

- Energy project acquisition and development advice to maximize benefits from state and local tax incentives including Chapter 312 and Chapter 313 (now expired) value limitation work as well as qualifications for sales tax exemptions available to data centers and large data centers.

- Ongoing representation of major investors, lenders, and developers of billions of dollars on Texas renewable energy projects as lead and local counsel and provide due diligence on state sales tax compliance and state and local tax incentives and other aspects of such projects.

- Successful audit defense of retaliatory tax assessment against non-Texas life insurer resulting in allowance of foreign state’s investment credits.

- Numerous aircraft acquisitions, sales, and ongoing operations modeled to achieve best-available state sales, use, and property tax treatment under Chapter 163 of the Texas Tax Code.

- Planning and compliance with respect to Texas sales tax on services, including bundled “data processing” transactions.

- Non-lobby monitoring and advising on pending and proposed Texas tax legislation and policy.

- Travis County District Court victory establishing renewable energy construction company’s right to Texas franchise tax exemption under Section 171.056 of the Texas Tax Code.

Education