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Monday, May 20, 2013

Supreme Court Unanimously Reverses Third Circuit, Says PPL Can Claim Foreign Tax Credit for U.K. Windfall Tax

United States Supreme CourtThe U.S. Supreme Court today unanimously reversed the Third Circuit (665 F. 3d 60) and agreed with the taxpayer that the United Kingdom's Windfall Tax is a tax on income and thus qualifies for the § 901 foreign tax credit.  PPL Corp. v. Commissioner, No. 12-43 (U.S. May 20, 2013).

Prior TaxProf Blog coverage:

http://taxprof.typepad.com/taxprof_blog/2013/05/supreme-court.html

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Comments

Yikes -- looks like the professoriate was slightly off on this one.

Posted by: andy | May 20, 2013 2:26:20 PM