PPL Corp. and Subsidiaries v. Commissioner of Internal Revenue
| Docket No. | Op. Below | Argument | Opinion | Vote | Author | Term |
|---|---|---|---|---|---|---|
| 12-43 | 3d Cir. |
Feb 20, 2013 Tr.Aud. |
TBD | TBD | TBD | OT 2012 |
Issue: Whether, in determining the creditability of a foreign tax, courts should employ a formalistic approach that looks solely at the form of the foreign tax statute and ignores how the tax actually operates, or should employ a substance-based approach that considers factors such as the practical operation and intended effect of the foreign tax.
SCOTUSblog Coverage
- Argument recap: The Court does algebra, and hilarity ensues
- Argument preview: Giving credit where credit is due
- Petition of the day
| Date | Proceedings and Orders |
|---|---|
| May 9 2012 | Application (11A1064) to extend the time to file a petition for a writ of certiorari from June 7, 2012 to July 9, 2012, submitted to Justice Alito. |
| May 10 2012 | Application (11A1064) granted by Justice Alito extending the time to file until July 9, 2012. |
| Jul 9 2012 | Petition for a writ of certiorari filed. (Response due August 10, 2012) |
| Jul 30 2012 | Consent to filing of amicus curiae briefs, in support of either party or of neither party, received from counsel for the petitioner. |
| Jul 31 2012 | Order extending time to file response to petition to and including September 10, 2012. |
| Aug 7 2012 | Brief amici curiae of N. Jerrold Cohen, Carol P. Tello, and Shane A. Lord filed. |
| Aug 8 2012 | Brief amici curiae of Rosanne Altshuler, et al. filed. |
| Aug 10 2012 | Brief amici curiae of Southeastern Legal Foundation, et al. filed. |
| Sep 4 2012 | Brief of respondent Commissioner of Internal Revenue filed. |
| Sep 19 2012 | DISTRIBUTED for Conference of October 5, 2012. |
| Oct 3 2012 | DISTRIBUTED for Conference of October 26, 2012. |
| Oct 29 2012 | Petition GRANTED. |
| Dec 3 2012 | Consent to the filing of amicus curiae briefs, in support of either party or of neither party, received from counsel for the petitioner. |
| Dec 13 2012 | Joint appendix filed (2 volumes). (Statement of costs received.) |
| Dec 13 2012 | Brief of petitioner PPL Corporation and Subsidiaries filed. |
| Dec 14 2012 | Brief amici curiae of Patrick J. Smith, et al. filed. |
| Dec 18 2012 | SET FOR ARGUMENT ON Wednesday, Fedruary 20, 2013 |
| Dec 19 2012 | Brief amici curiae of Entergy Corporation, et al. filed. |
| Dec 20 2012 | Brief amicus curiae of American Electric Power Company, Inc. filed. |
| Dec 20 2012 | Brief amici curiae of Southeastern Legal Foundation, et al. filed. |
| Jan 4 2013 | CIRCULATED. |
| Jan 11 2013 | Record from U.S.C.A. for 3rd Circuit is electronic. |
| Jan 14 2013 | Brief of respondent Commissioner of Internal Revenue filed. (Distributed) |
| Jan 18 2013 | Brief amici curiae of Anne Alstott, et al. filed. (Distributed) |
| Jan 24 2013 | Record recieved from U.S. Tax Court. (4 boxes) |
| Feb 12 2013 | Reply of petitioner PPL Corporation and Subsidiaries filed. (Distributed) |
| Feb 20 2013 | Argued. For petitioner: Paul D. Clement, Washington, D. C. For respondent: Ann O'Connell, Assistant to the Solicitor General, Department of Justice, Washington, D. C. |





