Jason I. Diener

Special Counsel

New York, NY
156 West 56th Street
New York, NY 10019
P 212.237.1110 F 212.262.1215
P 212.237.1110 F 212.262.1215


Jason Diener advises clients in various industries on a variety of commercial business matters, including planning considerations regarding M&A transactions, corporate and tax aspects of joint ventures, and state and local tax issues. Mr. Diener has more than ten years of experience counseling companies and individuals regarding all aspects of the international tax rules, including Subpart F, PFICs, FATCA and FBAR compliance issues and tax treaties. Jason served as a law clerk at the United States Tax Court, Washington, D.C.

Representative Matters

  • Advised a U.S.-based global insurance brokerage and risk management services firm on the cross-border tax structure for a reinsurance brokerage joint venture
  • Reviewed and negotiated a “hydro-excavation” joint venture agreement involving a global asset management firm specializing in alternative investment strategies
  • Analyzed foreign tax credit position of multinational silicone product producer
  • Advised wholesale insurers on underwriting transactional tax insurance policies to private equity firms
  • Counseled large Chinese company on restructuring a $95 million EB-5 project
  • Advised non-U.S. individual on earnings-stripping structure for substantial U.S. real estate investments
  • Performed PFIC and other tax calculations for numerous streamlined filing compliance procedures submissions
  • Advised foreign national who is a U.S. resident on timing a stock sale to achieve favorable treaty-based position
  • Advised high-profile individual on admission to celebrity restaurant joint venture

Newsroom +

Publications +



  • LL.M., Tax, New York University School of Law, 2005
  • M.B.A., Boston University School of Management, 2002
  • J.D., cum laude, Boston University School of Law, 2001
  • B.A., Economics, magna cum laude, Phi Beta Kappa, Brandeis University, 1998


  • New York
  • New Jersey