PPL Corp. and Subsidiaries v. Commissioner of Internal Revenue
|Docket No.||Op. Below||Argument||Opinion||Vote||Author||Term|
Feb 20, 2013
|May 20, 2013||9-0||Thomas||OT 2012|
Holding: The one-time “windfall tax” imposed in 1997 by the United Kingdom on a group of companies privatized between 1984 and 1996 is creditable under Section 901 of the Internal Revenue Code, which (as relevant here) provides that any “income, war profits, and excess profits taxes” paid overseas are creditable against U.S. income taxes.
Plain English Summary:
Judgment: Reversed, 9-0, in an opinion by Justice Thomas on May 20, 2013. Justice Sotomayor filed a concurring opinion.
- Opinion analysis: U.S. underwrites U.K. tax on privatized energy industry (Allison Christians)
- Argument recap: The Court does algebra, and hilarity ensues (Allison Christians)
- Argument preview: Giving credit where credit is due (Allison Christians)
- Petition of the day (Ben Cheng)