Clark Armitage Comments on MAP Process in Law360

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).


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