"Jason Osborn has been an exceptional advisor with the U.S. Competent Authority and on general Controversy matters."Legal 500
Jason Osborn is a partner in Mayer Brown’s Washington DC office and a member of the firm’s Tax Controversy & Transfer Pricing Practice. He provides sophisticated transfer pricing and international tax advice to multinational clients in a wide range of industries, including financial institutions, pharmaceuticals, consumer products, 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 is extensive and includes both IRS and foreign government-initiated transfer pricing disputes, as well as issues involving permanent establishments, withholding, residency and limitation on benefits.
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 topics related to transfer pricing, APAs, competent authority and the OECD’s Base Erosion and Profit Shifting (BEPS) and Digital Tax projects. He is also an editor and frequent contributor to “Best Methods,” Mayer Brown’s blog on Transfer Pricing Law and Policy.
Notre Dame Law School, JD, magna cum laude
Articles Editor, Notre Dame Law Review
Hamilton College, BA, summa cum laude
Phil Beta Kappa