J. Clark Armitage, an experienced lawyer in the transfer pricing sector, joined Caplin & Drysdale as a Member in 2013. Mr. Armitage's core practice is advising multinational corporations on transfer pricing in all contexts, from planning to cross-border dispute resolution. He has a particularly strong background interacting with tax authorities on advance pricing agreements (APAs) and Competent Authority matters for corporations in a wide range of industries.
Mr. Armitage spent eight years in the IRS Advance Pricing Agreement Program, serving as Deputy Director from 2008 to 2010, where he both experienced and oversaw the full spectrum of Program activities. He also served a special detail as the Tax Treaty Manager responsible for Canadian Competent Authority cases.
Drawing on his combined background in government and private practice, Mr. Armitage plays a key role in helping clients address transfer pricing, valuation, permanent establishment, and other international tax issues and controversies.
Mr. Armitage is a co-author of Bloomberg BNA Tax Management’s Portfolio 6955: “The Transfer Pricing Rules and Practice in Ireland”. He has also authored "The APA Program's Experience With Rev. Proc. 2008-31: Increased Opportunities for Certainty," which appeared in the Bloomberg BNA Tax Management Memorandum, November 7, 2011.
Mr. Armitage is an adjunct professor with the Georgetown University LL.M. Program, where he co-teaches "Introduction to Transfer Pricing." An avid lecturer on the topic of transfer pricing, Mr. Armitage also speaks before professional associations and at conferences.
Education:
J.D., The George Washington University Law School (1990)
B.A., American University (1987)
Bloomberg BNA Tax Management Portfolios:
6955 T.M., Transfer Pricing: Rules and Practice in Selected Countries (H-I) (co-author)