Legal Opinion
Entergy Corp. & Affiliated Subsidiaries v. Commissioner
Court of Appeals for the Fifth Circuit
Decided June 5, 2012No. 10-60988PublishedCited by 2 opinions
1Opinion of the Court
EDITH H. JONES, Chief Judge:
Appellant Commissioner of Internal Revenue (“Commissioner”) seeks review of a United States Tax Court decision favoring Appellee Entergy Corp. (“Entergy”) for the taxable years 1997 and 1998. By reference to a companion case, PPL Corp. v. Comm’r, 135 T.C. 304, 2010 WL 3565195 (2010), rev’d, 665 F.3d 60 (3d Cir.2011), the Tax Court concluded Entergy was entitled to a foreign income tax credit for its subsidiary’s payment of the United Kingdom’s Windfall Tax. The sole question on appeal is whether the Windfall Tax constitutes a creditable foreign income tax under…
2Cases cited5 opinions
- Terrell v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
- Bank of America National Trust & Savings Ass'n v. United StatesUnited States Court of Claims · 1972
- Inland Steel Co. v. United StatesUnited States Court of Claims · 1982
- PPL Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 2010
- PPL Corp. v. CommissionerCourt of Appeals for the Third Circuit · 2011
3Cited by2 opinions
- PPL Corp. v. Comm'r of Internal RevenueSupreme Court of the United States · 2013
- PPL Corp. v. Comm'r of Internal RevenueSupreme Court of the United States · 2013