"Jason Osborn has been superb in representing us before APMA in a major controversy with a treaty partner . . . A key quality of Jason’s is that he anticipates what both the client and the taxing authority are expecting, thereby saving time in crafting responses."Legal 500
Jason Osborn is a partner in Mayer Brown’s Washington DC office and co-leader of the firm’s International Tax & Transfer Pricing team. He provides sophisticated transfer pricing and international tax advice to multinational clients in a wide range of industries, including financial institutions, pharmaceuticals, consumer products, software, technology, chemicals, energy and transportation.
Jason re-joined Mayer Brown in 2013 after holding positions with the Internal Revenue Service (IRS) as a team leader in the Advance Pricing Agreement (APA) Program and as a manager in the transfer pricing branch of the Office of Associate Chief Counsel (International). Prior to his IRS service, Jason was a senior Tax associate at Mayer Brown.
Jason’s practice includes:
APAs – Jason advises multinationals in negotiations for unilateral, bilateral and multilateral APAs with the IRS and other tax authorities. Over the course of his career, Jason has negotiated or advised on approximately 50 APAs, many of which have involved intangible property, financial transactions, restructurings, or other complex or novel factual, legal or economic issues.
Competent Authority – Jason regularly assists multinationals in resolving transfer pricing and other tax treaty issues through the competent authority process (mutual agreement procedure (MAP)) on favorable terms that avoid double taxation. His competent authority experience includes IRS and foreign government-initiated transfer pricing disputes, issues involving permanent establishments, withholding, residency and limitation on benefits issues.
Transfer Pricing Planning and Advice – Jason advises multinationals on the tax-efficient structuring of a wide range of related party transactions, including cost sharing arrangements, transfers of tangible and intangible property, intercompany services, financial transactions, and restructurings. In this connection, he frequently structures and advises on intercompany agreements and transfer pricing documentation studies.
Jason is a frequent speaker and author on a range of transfer pricing and international tax topics. He is a co-author of Tax Management Portfolio, No. 6936, Transfer Pricing: OECD Transfer Pricing Guidelines (subscription required) and is an editor and frequent contributor to “Best Methods,” Mayer Brown’s blog on Transfer Pricing Law and Policy.
Areas of Focus
February 28 –
“Transfer Pricing in 2022 – New Regulations: Maybe, New Disputes: Definitely.”
TEI Houston Tax School
June 01 – 042021
"Trends in Tax Information Exchange," IADC International Tax Seminar
IADC Tax Seminar
Notre Dame Law School, JD, magna cum laude
Articles Editor, Notre Dame Law Review
Hamilton College, BA, summa cum laude
Phil Beta Kappa
- District of Columbia
- New York