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10 Year Extended Statute of Limitations Period for US Foreign Tax Credits does not Extend to Foreign Tax Deductions

|Approved Changes|United States
United States

The Second Circuit has affirmed a district court decision holding that the special 10-year statute of limitations (SOL) period applies only to foreign tax credits and not for foreign tax deductions.

The taxpayer, Trusted Media Brands, had a net operating loss in the 2002 tax year and therefore no US tax liability to claim a foreign tax credit (FTC).  In 2011, the taxpayer filed an am…

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