Daily Tax Update - October 21, 2014: Claims Court Holds Foreign Tax Credit Limitation Period Runs From Tax Year in Which Income Received

Claims Court Holds Foreign Tax Credit Limitation Period Runs From Tax Year in Which Income Received:  On September 20, the US Court of Federal Claims held (in a reissued opinion) that Albemarle Corp. could not claim $825,846 in foreign tax credits because the 10-year statute of limitations under Section 6511(d)(3)(A) had passed.  The court held that the 10-year period began in 1997 and 1998, the years a Belgian subsidiary received payments that Albemarle believed were not subject to Belgian tax, and not in 2002 when the company reached an agreement with the Belgian tax authority and paid the tax liability. 

Albemarle Corp. et al. v. United States, Fed. Cl., No. 1:12-cv-00184

Senators Request Action on Tax Fraud by Identity Theft:  In a letter to IRS Commissioner John Koskinen, 15 US senators requested additional measures to reduce the risk of identity theft-related refund fraud.  The bipartisan group calls for accelerating the verification of tax return information, providing victims of tax-related identity theft with a single point of contact, and allowing taxpayer to “turn off” electronic filing.