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Special rules applicable to credit against income tax for foreign taxes

April 17, 2020 IRS Newsroom Tax

Revenue Ruling 2020-08 suspends Rev. Rul. 71-533 pending reconsideration of whether the ten-year limitations period provided by section 6511(d)(3)(A) of the Internal Revenue Code applies to claims for refund or credit of an overpayment resulting from a foreign tax credit (FTC) carryback arising as a result of a net operating loss (NOL) carryback from a subsequent year.  As part of this reconsideration, Rev. Rul. 68-150 is also being reconsidered and is suspended with respect to adjustments that arise from a change to the FTC limitation, including as the result of the correction of mathematical errors or the application of an NOL carryback.

It will appear in will be in IRB: 2020-19, dated 05/04/2020.

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