Crude Oil Traders Fend Off the Tax Man

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Why it matters

Core event: The Texas Thirteenth Court of Appeals ruled on January 8, 2026, that crude oil inventories stored in San Patricio County tank farms are exempt from local ad valorem property taxes, affirming trial court summary judgments in favor of the taxpayers under the U.S. Constitution's Import-Export Clause (Art. I, § 10, cl. 2).[1][2][3][6]

Parties involved: Plaintiffs were Gunvor USA LLC and Devon Gas Services, L.P. (as agent for Glencore Ltd.); defendant was the San Patricio County Appraisal District, which had assessed taxes on the oil. The crude originated from Permian Basin producers, arrived via pipeline, and was stored for loading onto non-Jones Act vessels for export along the Corpus Christi Ship Channel.[3][4][5]

Context and timeline: The district assessed taxes on millions of barrels stored temporarily to meet export terminal requirements like berthing and laycan windows, despite title passing at the farms and all oil having pre-committed foreign destinations. Taxpayers protested; the appraisal review board denied relief. Trial courts (156th District Court) granted summary judgment for exemption in 2024-2025; oral arguments occurred in 2025; appeals court affirmed on January 8, 2026, rejecting claims of non-transit due to Texas origin or storage volume, as storage served export necessities.[1][2][3][5][6]

Newsworthy now: Released just days ago (February 9 coverage), the decision shields oil traders from local taxes on export-bound inventories amid booming Permian exports, potentially impacting Texas coastal tax revenue and similar disputes (e.g., ongoing with Vitol, Marathon).[3][4][7]

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