Jason I. Diener advises public companies, closely held entities, family offices, entrepreneurs, and exempt organizations on complex tax and business matters.
Mr. Diener has significant experience representing entities in M&A transactions and reorganizations in a wide range of industries. He regularly counsels clients regarding a variety of real estate-related matters, including organizational divisions and succession planning, like-kind exchanges, partnership structuring, incentive compensation arrangements, disguised sales, unrelated business taxable income, and leasing transactions.
Mr. Diener advises domestic and foreign clients on many cross-border tax issues involving the anti-deferral rules, multi-national reorganizations, real estate ventures, treaty interpretation and qualification issues, U.S. taxable presence determinations, and tax withholding compliance.
As a former law clerk to a United States Tax Court judge, Mr. Diener represents taxpayers before the IRS and state tax agencies in audits, administrative appeals, and litigation.