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Direct Participation Programs (DPPs) in Oil and Gas: What Investors Need to Know

A DPP gives qualified investors direct ownership in oil and gas with pass-through tax treatment. Here's how they work and what to watch for.

By Bass Energy & ExplorationApril 7, 2025
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What Is a Direct Participation Program?

A direct participation program (DPP) is an investment structure that gives you ownership in a business operation — in this case, oil and gas drilling and production — with all income, deductions, and credits passing directly through to your personal tax return. No corporate-level tax. No double taxation.

In oil and gas, DPPs are structured as general partnerships, joint ventures, or tenancy-in-common arrangements. The investor receives a working interest, participates in revenue, bears a share of costs, and receives the full suite of tax deductions.

How DPPs Differ from MLPs, ETFs, and Stocks

Buying oil company stock or an ETF gives you dividends and capital gains. You do NOT get IDC deductions, percentage depletion, or the Section 469 active income exception. Those benefits exist only at the entity level and don't pass through to shareholders.

MLPs pass through some income but focus on midstream operations — pipelines, storage, processing. MLP distributions are return of capital until basis is depleted. No IDC deductions because MLPs don't drill wells. A DPP is the only structure putting you at the wellhead with direct access to every upstream tax benefit.

Pass-Through Tax Treatment

The partnership files Form 1065 but pays no entity-level tax. Each investor receives a Schedule K-1 showing allocable income, losses, deductions, and credits. In year one, your K-1 typically shows a net loss because IDC deductions (60-85% of well costs) exceed initial production revenue. That loss flows to your personal return.

In subsequent years, the K-1 shows production income minus operating expenses, ongoing depletion deductions (15% of gross revenue under IRC 613), and equipment depreciation. Most investors see net positive income from year two onward.

Program Types

Drilling programs fund new wells. Highest risk but strongest tax deductions and highest return potential. Development programs target proven reserves — lower risk, strong IDC benefits. Income programs acquire existing producing wells — limited to depletion and depreciation, but immediate cash flow.

Risks

DPPs carry real risk. Dry holes. Commodity price drops. Higher-than-projected operating costs. And DPP interests are illiquid — no public market exists. Plan to hold for the life of the well, which could be 15-30 years.

Operator risk is also real. Ask about track record, completion rate, and whether they invest alongside investors.

How BassEXP Structures Its Programs

BassEXP programs are working interest joint ventures — not limited partnerships. This preserves the Section 469 active income exception. Management participates at the same level as outside investors. We provide detailed AFEs, geological data, offset well comparisons, and transparent monthly reporting.

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Written by

Preston Bass

CEO

Preston Bass is the founder of Bass Energy Exploration (BassEXP) and an experienced operator in the private oil and gas sector. He helps qualified investors evaluate working-interest energy projects with a focus on disciplined execution, cost control, and transparent reporting. Preston also hosts the ONG Report (Oil & Natural Gas Report), where he breaks down complex oil and gas investing topics—including tax considerations and deal structure—into clear, practical insights.

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