Jason Osborn

Background

About Jason Osborn

Jason Osborn is a Tax partner in Mayer Brown’s Washington DC office and a 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, technology, chemicals, energy and transportation. 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. ATTORNEY ADVERTISING