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  • J.D., The George Washington University Law School, 1990
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J. Clark Armitage

Member, Washington, D.C.
(202) 862-5078
carmitage@capdale.com | v-card | PDF

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.

Highlights

During his eight years with the IRS APA Program, Mr. Armitage served as team leader, branch chief, and industry coordinator for three separate groups, as well as Deputy Director.  In these roles, he experienced virtually all aspects of the Program's activities.  Mr. Armitage led numerous IRS Teams — including, economists, auditors, division counsel representatives, and Competent Authority analysts — in the development, negotiation, and conclusion of APAs.  As a frontline supervisor, he reviewed APAs developed by other IRS teams and coordinated development of cases in the industry coordination groups for Financial Products, Pharmaceuticals and Medical Devices, and Auto and Auto Parts.  Additionally, Mr. Armitage had Program-wide responsibility for reviewing cases, coordinating technical issues with other branches of the Office of the Associate Chief Counsel (International), and helping ensure that substantive and procedural issues were addressed consistently across the Program.

Mr. Armitage's contributions to the APA Program were bolstered by his detail as a manager for the U.S. Competent Authority's Office of Tax Treaty where he was responsible for supervising and reviewing Competent Authority analysts with responsibility for Canadian cases.  In 2008, he was the APA Program's representative to the IRS Transfer Pricing Task Force, which brought together officials from across the IRS with responsibility for transfer pricing enforcement.  The Task Force made recommendations that resulted in substantial new hiring of international examiners, the creation of a specialty group of international examiners focused exclusively on transfer pricing, and the formation of a Transfer Pricing Council to coordinate transfer pricing issues across the IRS.

Before joining the APA Program, Mr. Armitage was senior vice president for a venture capital fund management company, and served in London on the U.S. Tax Desk of a major accounting firm.  He also has worked with several leading law firms.

Awards & Rankings

  • The Legal 500, Recommended, 2014-Present
  • The Legal 500, Top-Tier Firm, Tax - US Taxes - Contentious, 2014-Present
  • The Legal 500, International Tax Team of the Year, 2014 and 2015
  • Best Lawyers in America, 2019-Present
  • Acquisition International, Best for International Transfer Pricing Issues - Washington, D.C., 2015

Recent News

Click here for a full list of media coverage.

Speaking Engagements

An avid lecturer on the topic of transfer pricing, Mr. Armitage speaks before professional associations and at conferences. He formerly taught “Introduction to Transfer Pricing” as an adjunct professor for the Georgetown University Law Center. Recent engagements include:

Click here for a full list of speaking engagements.

Recent Publications

Click here for a full list of publications.

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