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Tax Analysts Quotes Clark Armitage on IRS Resignations Affecting U.S.-India Talks on MAP Cases

July 8, 2014, Tax Analysts

Caplin & Drysdale's J. Clark Armitage spoke with Tax Analysts regarding the recent leadership resignations at the IRS' Large Business and International Division which could have an adverse effect on U.S.-India negotiations about stalled treaty mutual agreement procedure cases. For the full article, please visit Tax Analysts' website (subscription required).

Excerpt taken from the article "IRS Resignations Could Affect U.S.-India Talks on MAP Cases" by Stephanie Soong Johnston for Tax Analysts.

According to J. Clark Armitage of Caplin & Drysdale, the resignations of key officials, especially Danilack, come at an "unfortunate time" for U.S.-India MAP negotiations.

"At a time when India has just elected a new government that has offered some hopeful signs about how it's going to treat multinational corporations, this would be the optimal time to be engaging the Indian tax administration and competent authority," said Armitage, deputy director of the IRS APA program from 2008 to 2010. "These departures mean that is going to be delayed."

Armitage said the departures of Maruca and Danilack could stall the momentum of positive developments in U.S.-India discussions. "Even once you've filled their shoes with a new set of managers, they're going to have to be cautious and gain an understanding of what's transpired already and make their own decisions about how to proceed," he said.


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