Skip to Main Content

Clark Armitage Comments on MAP Process in Law360

August 8, 2019, Law360 Tax Authority

American multinationals that are working with the U.S. and another country to resolve double-tax cases through a mutual agreement procedure, or MAP, should be mindful of several factors - including their own expectations and attitude - that could affect the process.

 . . .

"These people who work for the government are very overworked and they will not have the same understanding of the facts and methodologies for your particular case that you do," said Clark Armitage, an international tax attorney at Caplin & Drysdale.

He added, "You need to be prepared at all times to keep them informed about it, to remind them of how it operates and what the relevance is."

Delays in MAP cases are likely still inevitable. The U.S., for example, takes an average of almost 31 months to resolve a dispute, compared to the global benchmark of 24 months, according to the OECD.

However, companies can make an effort to ensure that they're not the source of the delay, according to Armitage.

For example, companies could make sure that they don't take months to get a response in "when you could do it in three weeks if you managed it properly," he said.

For the full article, please visit Law360’s website (subscription required).


About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
295 Madison Avenue
12th Floor
New York, NY 10017


This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
©2021 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)