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Jason Yen is an associate in the firm’s Washington, DC office. His practice focuses on international tax matters, including structural and transactional tax planning, and controversy matters before the Internal Revenue Service. Mr. Yen also advises financial institutions, multinational corporations, and industry groups on the application of the Foreign Account Tax Compliance Act (FATCA), and has participated in drafting comment letters regarding the implementation of FATCA.
In addition, Mr. Yen has a substantial pro bono practice representing tax-exempt and non-profit organizations on federal tax matters, including rules on lobbying and legislative activities, conducting activities abroad, and applying for and maintaining federal tax-exempt status.
Representative Matters
- For a Middle Eastern chemical distribution company, assisted in implementing a global marketing structure that minimized permanent establishment and transfer pricing risk over 25 countries.
- Advised foreign financial institutions on compliance with reporting and withholding requirements under FATCA.
- Advised a foreign banker association on FATCA requirements in connection with the negotiation of intergovernmental agreements (IGAs).
- Advised multinational corporations on the application of Subpart F and section 367 to the restructuring of foreign operations.
Pro Bono
- Assisted numerous non-profit organizations in obtaining and maintaining tax-exempt status.
- Advised section 501(c)(3) organizations on the permissibility of conducting lobbying activities.
- Advised a non-profit organization on tax credits for the rehabilitation of a historic structure.
Memberships and Affiliations
- Committee on Foreign Activities of U.S. Taxpayers, ABA Tax Section
Publications and Speeches
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