J. Clark Armitage is an experienced international tax lawyer with a focus on transfer pricing.
Mr. Armitage's core practice is advising multinational corporations from a wide range of industries on transfer pricing matters, including planning, audits and appeals, advance pricing agreements (APAs), and Mutual Agreement Procedures (MAPs). He has a particularly strong background in APAs, having served eight years in the IRS Advance Pricing Agreement Program, including as Deputy Director from 2008 to 2010.
Mr. Armitage also advises clients on other U.S. international tax issues. He is well-versed with issues arising under the Tax Cuts and Jobs Act of 2017, including GILTI, FDII, BEAT, and foreign tax credit basketing. He represents clients with residency issues before the IRS Treaty Assistance and Interpretation Team (“TAIT”), helps clients navigate the U.S. federal income tax implications of bona fide Puerto Rican residency and status under Puerto Rico Act 20, Act 22, Act 60, and Act 73, and advises on permanent establishment and similar exposures.
Highlights
During his tenure with Caplin and Drysdale, Mr. Armitage has worked on numerous APA and MAP cases, IRS audits and Appeals, other tax controversy work and tax planning for corporate and high net worth individual clients.
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. 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 a 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.
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. Mr. Armitage formerly taught “Introduction to Transfer Pricing” as an adjunct professor for the Georgetown University Law Center.
Admissions & Education
Bar & Court Admissions
- District of Columbia
- Maryland
Education
J.D., The George Washington University Law School, 1990
B.A., American University, 1987
Recognitions
Honors & Recognitions
- The Legal 500, Recommended, 2014-2023
- 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
- ITR World Transfer Pricing, Highly Regarded, 2020
Professional Activities & Affiliations
Other Professional Affiliations
Member, District of Columbia Bar Association
Member, Maryland Bar Association
Member, U.S. Council for International Business
