J. Clark Armitage

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.

Bar & Court Admissions

• District of Columbia
• Maryland

Education

J.D., The George Washington University Law School, 1990

B.A., American University, 1987

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

Other Professional Affiliations

Member, District of Columbia Bar Association

Member, Maryland Bar Association

Member, U.S. Council for International Business