PPL Corp. & Subsidiaries v. Commissioner
United States Tax Court
Held: The United Kingdom windfall tax enacted on July 2, 1997, and imposed on certain British utilities is a creditable tax under sec. 901, I.R.C.
1Opinion of the Court
Halpern, Judge:
PPL Corp. (petitioner) is the common parent of an affiliated group of corporations (the group) making a consolidated return of income. By notice of deficiency, respondent determined a deficiency of $10,196,874 in the group’s Federal income tax for its 1997 taxable (calendar) year and also denied a claim for refund of $786,804. The issues for decision are whether respondent properly (1) denied the claim for the refund, which is related to the creditability of the United Kingdom (U.K.) windfall tax paid by petitioner’s indirect U.K. subsidiary (the windfall tax issue), (2)…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Hartford Underwriters Insurance v. Union Planters Bank, N. A.Supreme Court of the United States · 2000
- BedRoc Limited, LLC v. United StatesSupreme Court of the United States · 2004
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3Cited by4 opinions
- PPL Corp. v. Comm'r of Internal RevenueSupreme Court of the United States · 2013
- Entergy Corp. & Affiliated Subsidiaries v. CommissionerCourt of Appeals for the Fifth Circuit · 2012
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- PPL Corp. v. Comm'r of Internal RevenueSupreme Court of the United States · 2013