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.
May 20, 2013 9-0 Thomas OT 2012
 
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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.

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Judgment: Reversed, 9-0, in an opinion by Justice Thomas on May 20, 2013. Justice Sotomayor filed a concurring opinion.

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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.   JudgmentReversed, 9-0, in an opinion by Justice Thomas on May 20, 2013. Justice Sotomayor filed a concurring opinion.
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