Jason Osborn is a Tax partner in the firm’s Washington DC office. He provides sophisticated transfer pricing and international tax advice to multinational clients in wide range of industries, including financial institutions, pharmaceuticals, chemicals, software, automotive, consumer products, energy and transportation.
Jason re-joined Mayer Brown in 2013 after holding transfer pricing-related positions with Internal Revenue Service (“IRS”) from 2008-2012, initially as a team leader in the Advance Pricing Agreement (“APA”) Program and subsequently as a manager in the transfer pricing branch of the Office of Associate Chief Counsel (International). Leveraging this IRS experience, Jason brings to the table a unique and insider’s perspective in advising clients on complex transfer pricing matters and negotiating APAs. Prior to his IRS service, Jason was a senior Tax associate at Mayer Brown focused on transfer pricing matters.
Jason’s practice includes:
APAs – Jason advises multinationals in negotiations for unilateral and bilateral APAs with the IRS and other tax authorities around the world. Over the course of his combined law firm and IRS career, Jason has negotiated or advised on approximately 50 APAs, many of which have involved intangible property, financial transactions, restructurings, or other transactions involving complex or novel factual, legal or economic issues.
Competent Authority – Jason regularly assists multinationals in resolving transfer pricing and other tax treaty issue disputes through the competent authority process on terms that avoid double taxation. His competent authority and treaty experience is broad and includes cases involving both IRS and foreign government-initiated transfer pricing adjustments, as well as other treaty issues such as permanent establishment, withholding and limitation on benefits issues.
Transfer Pricing Planning and Advice – Jason advises multinationals on the tax-efficient structuring and transfer pricing of a wide range of related party transactions, including cost sharing arrangements, transfers of tangible and intangible property, intercompany services, intercompany loans and guarantees, and cross-border 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 topics related to transfer pricing, APAs, competent authority and the OECD’s Base Erosion and Profit Shifting project.