FTC carryback eliminates interest on earlier underpayment of tax. (foreign tax credits): An article from: The Tax Adviser

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This digital document is an article from The Tax Adviser, published by American Institute of CPA's on November 1, 1996. The length of the article is 957 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 Federal Claims ruled in Fluor Corp. that carrying back foreign tax credits to a prior tax year and eliminating that year's underpayment of tax also eliminated the obligation to pay interest on the tax deficiency from the prior year. The Court looked to the legislative history and found that Congress had intended that the carryback should be considered deemed paid or accrued in the earlier tax year. Past cases that had required the interest to be paid involved tax law changes that did not address retroactive application so expressly.

Citation Details
Title: FTC carryback eliminates interest on earlier underpayment of tax. (foreign tax credits)
Author: Diane L. Renfroe
Publication: The Tax Adviser (Magazine/Journal)
Date: November 1, 1996
Publisher: American Institute of CPA's
Volume: 27 Issue: n11 Page: 671(2)

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