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This digital document is an article from The Tax Adviser, published by American Institute of CPA's on October 1, 1996. The length of the article is 733 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: The US Court of Claims ruled in Fluor Corp. that the taxpayer's carryback of foreign tax credits to a prior tax year eliminated both the deficiency and the interest on the deficiency for that year. Under IRC section 904(c), foreign tax credits are carried back as deemed taxes paid in the year the credits are carried back to. This treatment differs from the general carryback treatment of IRC section 6601(d). Taxpayers with foreign tax credits that have been applied to prior year deficiencies should investigate refund opportunities.

Citation Details
Title: Favorable court decision on FTC carrybacks may necessitate immediate action - refund potential.
Author: Kathy Everidge
Publication:The Tax Adviser (Magazine/Journal)
Date: October 1, 1996
Publisher: American Institute of CPA's
Volume: 27 Issue: n10 Page: 639(1)

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