The University of Houston Law Center Faculty

Bret Wells

Professor of Law
John Mixon Chair
Director, Tax Program

713 743 2502

J.D., with honors, University of Texas Law School
B.B.A., summa cum laude, Southwestern University

Professor Douglas Bret Wells is a Professor of Law and Law Foundation Professor of Law at the University of Houston Law Center. Professor Wells teaches in the area of federal income taxation, corporate taxation, and international taxation. Professor Wells also teaches and writes on Texas Oil and Gas Law.

Professor Wells is the lead co-author on one of the premier treatises on U.S. international taxation. See Joseph Isenbergh & Bret Wells, International Taxation: U.S. Taxation of Foreign Persons and Foreign Income (Wolters Kluwer 6th Ed. 2021). He has testified on international taxation issues to the Senate Finance Committee, the Senate Permanent Subcommittee on Investigations, and to the House Ways and Means Subcommittee on Select Revenue Measures.

Professor Wells places significant emphasis on teaching materials used in his courses. He is a co-author on four of the leading casebooks on federal taxation, including the following: (i) Daniel L. Simmons, Martin J. McMahon, Bradley T. Borden, and Bret Wells, Federal Income Taxation (Foundation Press 8th ed. 2020); (ii) Martin J. McMahon, Daniel L. Simmons, Charlene D. Luke, and Bret Wells, Federal Income Taxation of Corporations (Foundation Press 5th ed. 2019); (iii) Martin J. McMahon, Daniel L. Simmons, Charlene D. Luke, and Bret Wells, Federal Taxation of Partnerships and S Corporations (Foundation Press 6th ed. 2020); (iv) Martin J. McMahon, Daniel L. Simmons, Charlene D. Luke, and Bret Wells, Federal Income Taxation of Business Organizations (Foundation Press 5th ed. 2020);. Professor Wells is a co-author on a leading law student resource on international tax law. See Joseph Isenbergh & Bret Wells, International Taxation (Foundation Press Insights & Concepts Series, 4th ed. 2019).

Prior to joining the faculty, Professor Wells was an executive officer of a leading oil and gas service company where he had significant exposure to oil and gas issues in the upstream context. Since joining the faculty, Professor Wells has written repeatedly on Texas oil and gas issues with a particular focus on the legal challenges raised by today’s development in unconventional shale formations. Professor Wells also is a co-author on a leading casebook on Texas oil and gas law. See Jacqueline L. Weaver and Bret Wells, Texas Oil and Gas Law: Cases and Materials (LawCarta 2d Ed. 2021). Professor Wells is a frequent speaker at conferences on oil and gas law matters.

In 2020, Professor Wells became an elected member of the American Law Institute.

Selected Tax Publications
Reform of Section 355, 68 Am. U. L. Rev. 447 (2018)
Reform of Corporate Distributions in Subchapter C, 37 Virginia Tax Rev. 365 (2018)
International Tax Reform By Means of Corporate Integration, 20 Florida Tax Rev. 71 (2016)
The Foreign Tax Credit War, 2016 BYU L. Rev. 1895 (2016)
Revisiting §367(d): How Treasury Took the Bite Out of Section 367(d) and What Should Be Done About It,” 16 Florida Tax Rev. 519 (2014);
Tax Base Erosion: Reformation of Section 482’s Arm’s Length Standard, 15 Florida Tax Rev. 737 (2014) (with C. Lowell)
Pass-Through Entity Taxation: A Tempest in the Tax Reform Teapot, 14 Hous. Bus. & Tax L.J. 1 (2014)
Income Tax Treaty Policy in the 21st Century: Residence vs. Source, 5 Colum. Tax J. 1 (2013) (with C. Lowell)
Territorial Taxation: Homeless Income is the Achilles Heel, 12 Hous. Bus. & Tax L.J. 1 (2012)
Disposable Personal Goodwill, Frosty the Snowman, and Martin Ice Cream All Melt Away in the Bright Sunlight of Analysis, 91 Neb. L.  Rev. 170 (2012) (with C. Bergez)
Tax Base Erosion and Homeless Income: Collection at Source is the Linchpin, 65 Tax L. Rev. 535 (2012) (with C. Lowell)
New Schedule UTP: Uncertain Tax Positions in the Age of Transparency, 63 Baylor L. Rev. 392 (2011)
Economic Substance: How Codification Changes Decided Cases, 10 Florida Tax Rev. 411 (2010)
Voluntary Compliance: This Return Might Be Right But Probably Isn’t, 29 Virginia Tax Rev. 645 (2010)

Selected Texas Oil and Gas Publications
The Exceptions Prove the Rule: Recalibrating the Discovery Rule and Equitable Fraud Exceptions to the Legal Injury Rule, 71 Baylor Law Rev. 63 (2019)
Abandoned But Not Forgotten, Improperly Plugged and Orphaned Wells May Pose Serious Concerns for Shale Development, 8 Mich. J. Env. & Admin. L. 115 (2018) (with T. Hester)
Allocation Wells:  Lessor’s Remedies for Multi-Tract Horizontal Wells Drilled Without Pooling Authority, 68 Baylor Law Rev. 1 (2016)
The Dominant Mineral Estate in the Horizontal Well Context: Time to Extend Moser Horizontally, 53 Hous. L. Rev. 193 (2015)
Please Give Us One More Oil Boom – I Promise Not to Screw It Up This Time: The Broken Promise of Casinghead Gas Flaring in the Eagle Ford Shale, 9 Tex. J. Oil, Gas & Energy Law 319 (2014).

COURSES:
Federal Income Taxation
Corporate Taxation
International Taxation
Oil and Gas Law