The U.S. IRS published a written determination on 20 August 2021 regarding the assessment statute for prior years following election to claim foreign tax credits. The written determination is in the form of a memorandum from the IRS Office of Chief Counsel and includes the following facts and conclusions: --- FACTS Taxpayer Advocate Services requested advice concerning the Service's refusal to process amended corporate tax returns filed by Taxpayer in ------- that show U.S. tax deficiencies for the ------- and ------- taxable years. In -------, Taxpayer filed amended returns for its ------- through ------- taxable years that reflect changes in...