Jason Osborn is a tax partner in the firm’s Washington, DC, office focusing primarily on transfer pricing and other international tax issues. He represents multinational clients in a wide range of industries in negotiations for bilateral advance pricing agreements (APAs) and in transfer pricing controversies. He also provides multinational clients with sophisticated international tax planning services. His transfer pricing experience and insight is extensive and varied and includes cost sharing arrangements, transfers of tangible and intangible property, intercompany services, intercompany loans and guarantees, global dealing and cross-border restructurings. His industry experience includes pharmaceuticals, software, electronics, financial institutions, insurance, automotive, consumer products, energy and transportation, among other industries. Jason served from 2008 through 2012 in the IRS Office of Associate Chief Counsel (International), most recently as senior technical reviewer in the transfer pricing branch, and before that, as a team leader in the APA Program. In this connection, he provided technical and strategic guidance and advice to the IRS in matters related to transfer pricing, negotiated a significant number of complex APAs, and served as a member of the APA Program’s coordination group for financial institutions. Leveraging his recent government experience, Jason brings to the table a unique and current perspective in advising clients and negotiating APAs and resolutions of transfer pricing controversies.
Transfer Pricing 2020
Covering the latest developments in transfer pricing law across 14 jurisdictions, this volume contains updates on topics including: transfer pricing methods, OECD Transfer Pricing Guidelines, permissible cost-sharing arrangements, transfer pricing adjustment rules, “safe harbour” methods, required disclosures and documentation, agencies responsible for enforcement, income tax treaty networks, relief (and its limitations) from double taxation, advance pricing agreements, and any potential tax exemptions or rate reductions available via government bodies.
Published in August 2019, this edition features the following chapters:
- United Kingdom
- United States