To what extent does IRC Section 6501(i) extend the statute of limitations for the carryback year? For example, if a 2010 excess foreign tax credit is carried back to 2009 does the 2009 year remain open for all potential adjustments until September 15, 2015 (1 year after the loss year) or just for the amount of the carryback?
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Kathryn Morgan
The use of an eligible carry back to a closed year does not reopen the rest of the return to other adjustments by the IRS only the item that was carried back and any items effected by that carry back.
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561 weeks ago