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Clark Armitage Moderates Panel on Eaton Decision Affecting APA Application at TP Minds Transfer Pricing Summit
Caplin & Drysdale

Clark Armitage Moderates Panel on Eaton Decision Affecting APA Application at TP Minds Transfer Pricing Summit

Date: 2/20/2018

Program:The APA Landscape: How "Eaton" Should Affect Your Next APA Application
Event Sponsor:TP Minds Americas
Where:

Biltmore Hotel - Miami

1200 Anastasia Avenue  

Coral Gables, FL 33134

Registration:Click Here To Register
The panel will address how the Tax Court’s Eaton decision affects the enforceability of APAs, as well as its impact on preparing submissions and compliance. The panel will discuss:

  • Whether the IRS may enforce an APA against the APA taxpayer
  • The burden of proof in cases involving an attempted rescission of an APA
  • Whether taxpayers’ obligations to provide an accurate and complete submission have changed; and
  • How to handle compliance issues in the APA Annual Report process.

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