Photo of Damon M. Lyon

Damon M. Lyon focuses his practice on cross-border mergers and acquisitions, global planning and international controversies for multinational companies. He advises clients on a broad range of tax issues, including tax-efficient structuring of acquisitions, dispositions, financings, internal reorganizations and joint ventures. Damon also provides advice concerning multi-jurisdictional business structures, such as intangible holding companies and finance company structures. Read Damon M. Lyon's full bio.

On April 18, 2016, the Supreme Court denied certiorari in the foreign tax credit dispute involving Albemarle Corp.  We have previously written about the case here, here, and here, which involved the timeliness of claims for refund pursuant to Internal Revenue Code (IRC) section 6511(d)(3)(A)’s 10-year limitations period.

Generally, a taxpayer must