1. Home
  2. Browse Decisions
  3. S.Ct.
  4. 133 S.Ct.
  5. 133 S.Ct. 1897 (2013)
 

PPL CORP. v. C.I.R.

No. 12-43.

133 S.Ct. 1897 (2013)

185 L.Ed.2d 972

PPL CORPORATION and Subsidiaries, Petitioners v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided May 20, 2013.

Attorney(s) appearing for the Case

Paul D. Clement, Washington, DC, for Petitioners.

Ann O'Connell, for Respondent.

Ashley C. Parrish, King & Spalding LLP, Washington, DC, Richard E. May, Mark B. Bierbower, Timothy L. Jacobs, Hunton & Williams LLP, Washington, DC, Paul D. Clement, Counsel of Record, Erin E. Murphy, Bancroft PLLC, Washington, DC, for Petitioners.

Donald B. Verrilli, Jr., Solicitor General, Kathryn Keneally, Assistant Attorney General, Malcolm L. Stewart, Deputy Solicitor General, Ann O'Connell, Assistant to the Solicitor General, Counsel of Record, Thomas J. Clark, Francesca U. Tamami, Attorneys, Department of Justice, Washington, DC, for Respondent.

Justice THOMAS delivered the opinion of the Court.

In 1997, the United Kingdom (U.K.) imposed a one-time "windfall tax" on 32 U.K. companies privatized between 1984 and 1996. This case addresses whether that tax is creditable for U.S. tax purposes. Internal Revenue Code § 901(b)(1) states that any "income, war profits, and excess profits taxes" paid overseas are creditable against U.S. income taxes. 26 U.S.C. § 901(b)(1). Treasury Regulations interpret this...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases