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 amended 2002 return changing its election from a credit to a deduction for foreign taxes paid. This increased its claimed 2002 NOL from $13 million to $74.4 million, which the taxpayer carried back to its 1997...