[Code of Federal Regulations]
[Title 26, Volume 18]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR301.6511(d)-3]

[Page 382]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 301_PROCEDURE AND ADMINISTRATION--Table of Contents
 
                               Limitations
 
Sec. 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.