Foreign Tax Credit Refund Claim Denied as Untimely

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Our International Tax Group discusses a recent case that offers a cautionary tale on statutory limitations periods and shows how even seemingly straightforward provisions are open to interpretation.

  • 10 years vs. three years vs. two years?
  • When is a refund “attributable to” foreign taxes?
  • What does it mean to “pay” taxes?

Read the full advisory here.