News & Analysis as of

Limitation Periods Tax Liability

A&O Shearman

Unilateral notice under an SPA not sufficient to stop limitation period expiring

A&O Shearman on

A unilateral notice relating to a tax liability under a share sale and purchase agreement was not a valid notice within the relevant limitation period for a claim. The construction of a unilateral notice must be viewed...more

McDermott Will & Emery

Federal Circuit Narrowly Interprets Limitations Period for Foreign Tax Credit Refund Claims

In Albemarle Corp. v. United States, No. 2015-5015 (Fed. Cir. Aug. 13, 2015), the United States Court of Appeals for the Federal Circuit disallowed claims for refund related to foreign taxes paid by Albemarle Corporation...more

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