Allison Christians is the H. Heward Stikeman Chair in Tax Law, McGill University Employing what Justice Thomas calls a “commonsense approach,” yesterday the Court unanimously decided in favor of the taxpayer with respect to the creditability of a foreign tax in PPL Corp & Subsidiaries v. Commissioner.
Yesterday, the Court heard arguments in PPL Corp. and Subsidiaries v. Commissioner, which examines the issue of how the US tax system should treat taxes paid to foreign governments. My argument preview, which outlines the issues and the parties’ arguments, may be found here.
Allison Christians is the H. Heward Stikeman Chair in Tax Law, McGill University On February 20, the Supreme Court will hear oral arguments in PPL Corp. and Subsidiaries v. Commissioner, in which it will consider how, and how well, Congress has defined rules under which the United States reduces tax on Americans who pay foreign taxes on income earned abroad.