Clark Armitage Moderates Panel on How Eaton Decision and U.S. Tax Reform are Affecting APAs at TP Minds Americas


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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