Jason M. Osborn

APAs: Multinationals seeking tax certainty on their most complex, business critical and highest value intercompany transactions turn to Jason to guide them through the advance pricing agreement (APA) process with the IRS APMA Program and other tax authorities around the world. Multinationals particularly value Jason's approximately 20 years combined law firm and government experience negotiating or advising on over 50 unilateral, bilateral and multilateral APAs, many of which involve intangible property, financial transactions, restructurings, or other complex or novel factual, legal or economic issues.

Competent Authority: Multinationals rely on Jason to resolve 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 business restructurings. Clients frequently trust him to structure and advise 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 and is co-author of Tax Management Portfolio, No. 6936, Transfer Pricing: OECD Transfer Pricing Guidelines. His prior experience includes working with the Internal Revenue Service (IRS) as an Advance Pricing Agreement (APA) Program team leader, and as a manager in the transfer pricing branch of the Office of Associate Chief Counsel (International).

Clients served by Jason include some of the world's largest US and non-US based multinationals in the financial services, life sciences, software, technology, consumer products, and transportation among other industries.