Overview
Second Circuit Holds 10-Year Limitations Period Does Not Apply to Deduction for Foreign Taxes: In Trusted Media Brands, Inc. v. United States, No. 17-3733-cv, the Second Circuit held that the special ten‐year limitations period on refund claims resulting from foreign tax credits under section 6511(d)(3)(A) is not applicable to claims resulting from deductions for foreign taxes paid or accrued.
IRS Issues Updated Weighted Average Interest Rates, Yield Curves, and Segment Rates: Notice 2018-65 provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under section 417(e)(3), and the 24-month average segment rates under section 430(h)(2). The notice also provides guidance as to the interest rate on 30-year Treasury securities under section 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008 and the 30-year Treasury weighted average rate under section 431(c)(6)(e)(ii)(I).