Piggybacking
On the last day of the special session, Glenfarne issued a press release opposing the S Corp tax. Read it carefully. It isn't just protecting Glenfarne's financing structure. It's protecting Hilcorp's tax exemption — and Hilcorp signed a gas supply agreement with Glenfarne. One press release. Two private pass-through entities. Both winners if it works.
The special session ends today. The Senate has still not reached the 11 votes needed from its 14-member majority coalition to pass the LNG tax bill. The confidential AGDC-Glenfarne agreement landed in senators' hands yesterday, halting the floor session. And this morning Glenfarne issued a press release threatening that the S Corp tax amendment kills the project's financing.
On the last day of a session called to pass a tax bill built on unverified costs, Glenfarne is protecting not just its own structure — but the tax position of one of its own gas supply partners.
Glenfarne's press release this morning is brief. Four sentences. It warns that an S Corp pass-through entity tax would introduce "major hurdles" for Alaska LNG financing, "increase financial burdens on the project," and "signal uncertainty to investors." It closes with a warning that a "poorly constructed pass-through entity tax change would be shortsighted when the State is on the verge of the largest capital raise initiative for energy infrastructure in U.S. history."
Read at face value it is a developer protecting its financing structure on the last day of the session. Read carefully it is something else entirely — a single press release that simultaneously protects two private pass-through entities, one of which signed a gas supply agreement with the other, both of which benefit from the same tax exemption, and neither of which has told Alaska's legislature what this project actually costs to build.
That is not coincidence. That is piggybacking.
"If the Senate passes a bill with the proposed S Corp tax, it will introduce major hurdles for Alaska LNG to secure the right financing to build the project. The S Corp tax increases financial burdens on the project and signals uncertainty to investors."
"A broad tax on all pass-through entities would have unintended consequences that would negatively impact new investment in Alaska including renewables, data centers, and other energy infrastructure projects. A poorly constructed pass-through entity tax change would be shortsighted when the State is on the verge of the largest capital raise initiative for energy infrastructure in U.S. history."
Two Private Companies. Same Tax Structure. One Press Release.
To understand why this press release protects two entities simultaneously, you need to understand what the S Corp tax actually is and who it hits.
Alaska's corporate income tax applies to C corporations — the standard corporate structure used by publicly traded companies like ConocoPhillips, ExxonMobil, and BP. It does not apply to pass-through entities — S corporations, LLCs, and partnerships — whose profits pass through to owners without triggering Alaska corporate income tax at the entity level.
The Senate's S Corp amendment, championed by Senator Forrest Dunbar, would close that loophole for oil and gas companies. It has been modeled to generate over $100 million per year in new state revenue. The largest single company affected is Hilcorp — the privately held Texas company that operates Prudhoe Bay and most Cook Inlet oil and gas production — which pays no Alaska corporate income tax because it is structured as an S corporation.
Glenfarne Alaska LNG LLC is a pass-through LLC. It too would be caught by the same provision.
The Relationship That Makes This Piggybacking
Hilcorp signed a gas sales precedent agreement with Glenfarne. That agreement commits Hilcorp's North Slope associated gas to the Alaska LNG project — conditionally, as this series has documented, structured as a safety net rather than a binding commitment. The agreement requires FID. FID requires financing. Financing requires the tax bill. And the tax bill — in Glenfarne's preferred form — excludes the S Corp amendment that would cost Hilcorp over $100 million per year.
So Hilcorp's gas supply agreement with Glenfarne and Hilcorp's S Corp tax exemption are now linked through the same piece of legislation on the last day of the same special session. If Glenfarne's press release succeeds — if the Senate drops the S Corp amendment to pass the tax bill — Hilcorp wins twice simultaneously. The project that will monetize its stranded gas advances. And its annual tax exemption worth over $100 million is preserved.
Hilcorp Wins Either Way
This series has documented how the North Slope producers — including Hilcorp — structured their gas supply agreements as safety nets. If the project fails, the agreements expire with no loss. If the project succeeds, the gas gets monetized. The producers built optionality, not commitment.
Today's S Corp fight adds a third dimension to Hilcorp's position. It now wins in three distinct scenarios on the same day.
The Largest Capital Raise in U.S. History
Glenfarne's press release closes with a remarkable claim — that Alaska is "on the verge of the largest capital raise initiative for energy infrastructure in U.S. history." That claim deserves to be examined on the last day of the session.
Glenfarne Group has raised $48.5 million in its entire corporate history. It has no binding buyer contracts — all offtake agreements are letters of intent. It has no confirmed project financing. It missed its own FID deadline by at least six months. It acknowledges that verified project costs won't be available until mid-2027. Its publicly traded partners — Danaos, Baker Hughes, TotalEnergies — have made strategic commitments, not binding financing commitments.
The largest capital raise in U.S. history has not been arranged. It has been announced — on a press release — on the last day of a special session — by a company with $48.5 million in total fundraising — to pressure the Alaska Senate into dropping a revenue measure that would protect state services and close a tax loophole that benefits one of Glenfarne's own gas supply partners.
That is not a financing announcement. That is a political statement. And it is doing double duty — protecting Glenfarne's LLC structure and Hilcorp's S Corp exemption simultaneously with four sentences and a logo.
What the Senate Should See Clearly
The S Corp amendment raises over $100 million per year. The property tax bill it is attached to gives Glenfarne a 90% property tax reduction worth hundreds of millions more over 30 years. The Senate is being asked to drop the $100 million annual revenue measure — framed as protecting Alaska LNG financing — on the last day of a session in which the confidential AGDC-Glenfarne agreement just landed in senators' hands and the floor session had to be halted.
The $100 million per year the S Corp tax would generate is not coming from Glenfarne alone. The largest share comes from Hilcorp — Prudhoe Bay's operator, Cook Inlet's dominant producer, and Glenfarne's gas supply partner. Hilcorp has said nothing publicly about the S Corp tax today. It doesn't need to. Glenfarne's press release is doing the work.
The Bill Alaska Is Being Asked to Sign
This series began with a simple observation in May 2007 — tax certainty requires known project costs. Nineteen years later, on the last day of a special session called to force that tax certainty through before costs are verified, the argument is the same.
The bill Alaska is being asked to sign today gives Glenfarne a 90% property tax reduction — based on unverified costs. It preserves Hilcorp's income tax exemption — worth over $100 million per year — as a byproduct of Glenfarne's press release. It locks in generational tax concessions built on arithmetic nobody has been allowed to check. And it does all of this on the same day senators finally got their hands on the confidential agreement that explains why nobody could check the arithmetic.
Two private pass-through entities. One press release. Zero verified costs. Nineteen years after I first wrote that tax certainty requires known project costs — Alaska is still being asked to set the tax before knowing the number.
That is what piggybacking looks like when it succeeds.
The question is whether the Alaska Senate lets it.

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