Treasury Regulations (26 C.F.R.)
26 CFR § 301.6511(d)-3
Special rules applicable to credit against income tax for foreign taxes.
# (a) Period in which claim may be filed.
In the case of an overpayment of income tax resulting from a credit, allowed under the provisions of section 901 or under the provisions of any treaty to which the United States is a party, for taxes paid or accrued to a foreign country or possession of the United States, a claim for credit or refund must be filed by the taxpayer within 10 years from the last date prescribed for filing the return (determined without regard to any extension of time for filing such return) for the taxable year with respect to which the claim is made. Such 10-year period shall be applied in lieu of the 3-year period prescribed in section 6511(a).
# (b) Limit on amount to be credited or refunded.
In the case of a claim described in paragraph (a) of this section, the amount of the credit or refund allowed or made may exceed the portion of the tax paid within the period prescribed in section 6511 (b) or (c), whichever is applicable, to the extent of the amount of the overpayment attributable to the allowance of a credit against income tax referred to in paragraph (a) of this section.
Source: view the official text
In this part (40 sections)
- 301.6501(i)-1 · Foreign tax carrybacks; taxable years beginning after…
- 301.6501(j)-1 · Investment credit carryback; taxable years ending after…
- 301.6501(m)-1 · Tentative carryback adjustment assessment period.
- 301.6501(n)-1 · Special rules for chapter 42 and similar taxes.
- 301.6501(n)-2 · Certain contributions to section 501(c)(3)…
- 301.6501(n)-3 · Certain set-asides described in section 4942(g)(2).
- 301.6502-1 · Collection after assessment.
- 301.6503(a)-1 · Suspension of running of period of limitation; issuance…
- 301.6503(b)-1 · Suspension of running of period of limitation; assets…
- 301.6503(c)-1 · Suspension of running of period of limitation; location…
- 301.6503(d)-1 · Suspension of running of period of limitation;…
- 301.6503(e)-1 · Suspension of running of period of limitation; certain…
- 301.6503(f)-1 · Suspension of running of period of limitation; wrongful…
- 301.6503(g)-1 · Suspension pending correction.
- 301.6503(j)-1 · Suspension of running of period of limitations;…
- 301.6511(a)-1 · Period of limitation on filing claim.
- 301.6511(b)-1 · Limitations on allowance of credits and refunds.
- 301.6511(c)-1 · Special rules applicable in case of extension of time…
- 301.6511(d)-1 · Overpayment of income tax on account of bad debts,…
- 301.6511(d)-2 · Overpayment of income tax on account of net operating…
- 301.6511(d)-3 · Special rules applicable to credit against income tax…
- 301.6511(d)-4 · Overpayment of income tax on account of investment…
- 301.6511(e)-1 · Special rules applicable to manufactured sugar.
- 301.6511(f)-1 · Special rules for chapter 42 taxes.
- 301.6512-1 · Limitations in case of petition to Tax Court.
- 301.6513-1 · Time return deemed filed and tax considered paid.
- 301.6514(a)-1 · Credits or refunds after period of limitation.
- 301.6514(b)-1 · Credit against barred liability.
- 301.6521-1 · Mitigation of effect of limitation in case of related…
- 301.6521-2 · Law applicable in determination of error.
- 301.6532-1 · Periods of limitation on suits by taxpayers.
- 301.6532-2 · Periods of limitation on suits by the United States.
- 301.6532-3 · Periods of limitation on suits by persons other than…
- 301.6601-1 · Interest on underpayments.
- 301.6602-1 · Interest on erroneous refund recoverable by suit.
- 301.6611-1 · Interest on overpayments.
- 301.6621-1 · Interest rate.
- 301.6621-2T · Questions and answers relating to the increased rate of…
- 301.6621-3 · Higher interest rate payable on large corporate…
- 301.6622-1 · Interest compounded daily.