J. Clark Armitage

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20 Feb 2025

IRS Transfer Pricing Guidance: Adjustments Based On Actual Results

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09 Jan 2025

IRS Notices Adoption Of Amount B; Transfer Pricing Penalties Still In Play

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09 Jan 2025

IRS Guidance On Source Of Gain Under Section 937

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05 Sep 2024

So You Think You're In Control: When Do Transfer Pricing Rules Apply?

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20 May 2024

Clark Armitage Discusses U.S. Tax Disputes Trends (Podcast)

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14 May 2024

Clark Armitage Discusses Cross-Border Transfer Pricing Disputes (Podcast)

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02 Apr 2024

Businesses Operating In Puerto Rico Must Consider Pillar Two

Worldwide Tax

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19 Feb 2024

Puerto Rico May Impose A 15% Minimum Tax On Business Income; What Will Happen To Act 60 Decrees?

Puerto Rico Tax

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25 Jan 2024

Crypto Form 8300 Filing Delay

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03 Nov 2023

Is ICAP A Viable Alternative To APAs?

United States Tax