[Code of Federal Regulations]
[Title 26, Volume 14]
[Revised as of January 1, 2007]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR20.2014-6]

[Page 259]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 20_ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 
1954--Table of Contents
 
Sec.  20.2014-6  Period of limitations on credit.

    The credit for foreign death taxes under section 2014 is limited to 
those taxes which were actually paid and for which a credit was claimed 
within four years after the filing of the estate tax return for the 
decedent's estate. If, however, a petition has been filed with the Tax 
Court of the United States for the redetermination of a deficiency 
within the time prescribed in section 6213(a), the credit is limited to 
those taxes which were actually paid and for which a credit was claimed 
within four years after the filing of the return, or before the 
expiration of 60 days after the decision of the Tax Court becomes final, 
whichever period is the last to expire. Similarly, if an extension of 
time has been granted under section 6161 for payment of the tax shown on 
the return, or of a deficiency, the credit is limited to those taxes 
which were actually paid and for which a credit was claimed within four 
years after the filing of the return, or before the date of the 
expiration of the period of the extension, whichever period is the last 
to expire. See section 2015 for the applicable period of limitations for 
credit for foreign death taxes on reversionary or remainder interests if 
an election is made under section 6163(a) to postpone payment of the 
estate tax attributable to reversionary or remainder interests. If a 
claim for refund based on the credit for foreign death taxes is filed 
within the applicable period described in this section, a refund may be 
made despite the general limitation provisions of sections 6511 and 
6512. Any refund based on the credit for foreign death taxes shall be 
made without interest.

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