Legal Opinion
PPL Corp. v. Commissioner
Court of Appeals for the Third Circuit
Decided December 22, 2011No. 11-1069PublishedCited by 3 opinions
1Opinion of the Court
OPINION OF THE COURT
AMBRO, Circuit Judge.
The Commissioner of Internal Revenue appeals a decision of the United States Tax Court holding that PPL Corporation was entitled to a foreign tax credit for the 1997 tax year under § 901 of the Internal Revenue Code. We agree with the Commissioner that the foreign tax before us does not qualify for a foreign tax credit, and thus reverse.
I. Background
PPL is a Pennsylvania corporation. In 1997, it held a 25% stake in SWEB (formerly South Western Electricity Board), a utility in the United Kingdom. SWEB was one of 32 United Kingdom companies subject to a…
2Cases cited11 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Helvering v. HorstSupreme Court of the United States · 1940
- Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
- Boulware v. United StatesSupreme Court of the United States · 2008
- Texasgulf, Inc., and Subsidiaries, as Successor in Interest to Texasgulf, Inc. And Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1999
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3Cited by3 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
- PPL Corp. v. Comm'r of Internal RevenueSupreme Court of the United States · 2013