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International Tax Blog - New and Interesting International Tax Issues


International PLRs / CCAs of the 4th week of 2012

2012-01-30

Last week the IRS published the following Chief Counsel Advice relating to international taxation:

CCA 201204008: A taxpayer's claim for refund of an overpayment was not timely where the taxpayer elected in a later year to deduct rather than credit foreign taxes paid in an earlier year, thereby generating an increased net operating loss carryback from the earlier year.

Tags: Authority - PLRs / CCAs