On September 20, the US Court of Federal Claims held (in a reissued opinion) that Albemarle Corp. could not claim $825,846 in foreign tax credits because the 10-year statute of limitations under Section 6511(d)(3)(A) had passed. The court held that the 10-year period began in 1997 and 1998, the years a Belgian subsidiary received payments that Albemarle believed were not subject to Belgian tax, and not in 2002 when the company reached an agreement with the Belgian tax authority and paid the tax liability.
Albemarle Corp. et al. v. United States, Fed. Cl., No. 1:12-cv-00184