Jason Yen

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Jason Yen is an associate in the firm’s Washington, DC office, practicing in the tax and election and political law practice groups.  Mr. Yen advises clients regarding the Federal income tax aspects of domestic and international transactions and structures and represents clients before the Internal Revenue Service and the Treasury Department.  Mr. Yen also advises corporate and political clients on the Federal tax aspects of lobbying and political activities.

Mr. Yen has a substantial pro bono practice representing tax-exempt and not-for-profit organizations on tax matters, including lobbying and legislative activities, conducting activities abroad, and applying for and maintaining federal tax-exempt status.

Representative Matters

• Advising a domestic borrower on its withholding obligations in connection with the Foreign Account Tax Compliance Act (FATCA).
• Advising a multinational company regarding the application of Subpart F to a restructuring transaction.
• Advising a financial institution on the tax aspects of a transaction to raise Tier 1 capital.
• Advising an organization on state laws related to political contributions and expenditures.

Pro Bono

• Assisting various non-profit organizations in obtaining and maintaining tax-exempt status.
• Advising various section 501(c)(3) organizations on the permissibility of conducting lobbying activities.
• Advising a non-profit organization on tax credits for the rehabilitation of a historic structure.
• Advising a legal-services organization on professional conduct rules related to non-lawyer participation.

Publications and Speeches

• "‘Rodriguez’ Holds Section 951 Inclusions Not Qualified Dividend Income; CFC Components of Proposed Rules Under Section 1411 Now Unlikely to Change," Bloomberg BNA's Daily Tax Report (7/26/2013), Author
• "The Senate Permanent Subcommittee on Investigations Reportedly Plans Campaign Finance Investigation," Covington Advisory (4/4/2013), Co-Author
• "District Court’s ‘AIG’ Ruling Expands Application of Economic Substance Doctrine In Unexpected Ways for Transactions Generating Excess Foreign Tax Credits," Bloomberg BNA Daily Tax Report (2013), Co-Author