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Adoption Credit: Prior to its redesignation as IRC Sec. 36C , the adoption credit under former IRC Sec. 23 was nonrefundable, but had a five-year carryforward. For tax years 2010 and 2011, the credit was made refundable. The IRS indicated in this emailed advice that a carryforward of credit from a nonrefundable year to 2010 or 2011, to the extent no tax benefit could have been obtained through the filing of a timely claim for refund, entitled the taxpayer to a refundable credit in those years. For example, a taxpayer who met all the criteria for claiming the adoption credit in 2005, but had no tax liability for any of the years 2005–2010, would be entitled to a refundable credit of the entire 2005 amount in 2010. CCA 201211021 .