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Clark Armitage Speaks to Bloomberg BNA: GOP Tax Overhaul Could Throw U.S. Tax Treaties into Question

February 3, 2017, Bloomberg BNA

A Republican plan to overhaul the U.S. corporate income tax could put the dozens of existing U.S. double-tax treaties in limbo.

U.S. companies doing business abroad may no longer be able to rely on the mechanisms in treaties for resolving cross-border tax disputes—overlapping claims on a company's tax—or they may become one-sided. The issue is one of many technical and practical concerns practitioners are struggling to understand as the broadly outlined plan is debated.

‘Revolutionary’ Changes?

“There's a very serious question about whether these changes are not evolutionary but revolutionary, and would cause the tax to not be covered by the treaties,” said J. Clark Armitage, a transfer pricing and dispute resolution attorney with Caplin & Drysdale in Washington.

For the full story, please visit Bloomberg BNAs website (subscription required).

Excerpt taken from the article “GOP Tax Overhaul Could Throw U.S. Tax Treaties into Question” by Alex M. Parker for Bloomberg BNA.


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