FacultyFaculty/Author Profile
Jason R. Connery

Jason R. Connery

KPMG LLP

Washington, DC, USA


Jason is a principal in the International Tax group of KPMG LLP’s Washington National Tax practice. Prior to rejoining KPMG in 2006, Jason was a Director of the Structured Finance Group at an investment bank in New York City, where he developed and implemented cross-border financings for the Bank. Prior to that, he was with the International Corporate Services group of KPMG’s Washington National Tax practice.

Professional and Industry Experience

  • Jason advises non-U.S.-based multinational companies on a wide range of matters, including U.S. trade or business determinations, debt vs. equity determinations, branch taxation, sourcing of income, allocation and apportionment of expenses, earnings stripping, and repatriation.
  • He routinely advises on U.S. income tax treaty issues, including eligibility of treaty benefits when payments of U.S. source income are made to fiscally transparent entities and/or hybrid entities.
  • He provides tax advice to U.S.-based multinational companies on matters involving offshore earnings deferral, foreign tax credits, subpart F, foreign currency and interest rate risk management in offshore treasury centers.

Publications and Speaking Engagements

  • Co-author, Current Status of U.S. Tax Treaties and International Tax Agreements, Tax Mgmt. Int’l J. [monthly publication].
  • Co-author, Container Corp. - Tax Court Provides Needed Guidance on Sourcing of Guarantee Fees, 21 J. Int’l Tax’n 26 (July 2010).
  • Co-author, Getting the Deal Through, Tax on Inbound Investment 2013-2016.
  • Co-author, Eligibility for Treaty Benefits Under the Mexico-U.S. Income Tax Treaty, Tax Notes Int’l, June 27, 2016, p. 1285.
  • Co-author, Eligibility for Treaty Benefits Under the Denmark-U.S. Income Tax Treaty, Tax Notes Int’l, June 29, 2015, p. 1219.
  • Co-author, Eligibility for Treaty Benefits Under the Belgian-U.S. Income Tax Treaty, Tax Notes Int’l, February 10, 2014, p. 563.
  • Co-author, Eligibility for Treaty Benefits Under the Ireland-U.S. Income Tax Treaty, Tax Notes Int’l, June 17, 2013, p. 1223.
  • Co-author, Eligibility for Treaty Benefits Under the Sweden-U.S. Income Tax Treaty, Tax Notes Int’l, July 23, 2012, p. 359.
  • Co-author, Eligibility for Treaty Benefits Under the Australia-U.S. Income Tax Treaty, Tax Notes Int’l, Dec. 12, 2011, p. 843.
  • Co-author, Eligibility for Treaty Benefits Under the Switzerland-U.S. Income Tax Treaty, Tax Notes Int’l, May 9, 2011, p. 505.
  • Co-author, Eligibility for Treaty Benefits Under the Japan-U.S. Income Tax Treaty, Tax Notes Int’l, Sept. 6, 2010, p. 789.
  • Co-author, Eligibility for Treaty Benefits Under the 2009 Protocol to the France-U.S. Income Tax Treaty, Tax Notes Int’l, Apr. 12, 2010, p. 149.
  • Co-author, Eligibility for Treaty Benefits Under the Netherlands-U.S. Income Tax Treaty, Tax Notes Int’l, Nov. 23, 2009, p. 601.
  • Co-author, Eligibility for Treaty Benefits Under the Canada-U.S. Income Tax Treaty, Tax Notes Int’l, June 15, 2009, p. 967.
  • Co-author, Eligibility for Treaty Benefits Under the Luxembourg-U.S. Income Tax Treaty Tax Notes Int’l, July 21, 2008, p.285.
  • He is a frequent speaker at conferences on U.S. international tax issues.

Education

  • New York University School of Law, LL.M. in taxation
  • The John Marshall Law School, J.D., cum laude
  • University of Florida, B.S. in accounting, with honors
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