J. Clark Armitage, an experienced lawyer in the transfer pricing sector, joined Caplin & Drysdale as a Member in 2013. He was named President of the Firm in October 2018.
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 on 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.