Cross-Border Tax Issues and Creditability of Foreign Taxes

Scotusblog has an analysis of PPL Corp. & Subsidiaries v. Commissioner, a recent decision of the U.S. Supreme Court.  In PPL Corp., the Court held that a U.S. company that owned a large interest in a U.K. energy concern is allowed to credit against its “windfall tax” paid to the U.K. government in 1997 against its U.S. income tax. The ruling reversed the judgment of the U.S. Court of Appeals for the Third Circuit but was consistent with decisions by the Tax Court and the U.S. Court of Appeals for the Fifth Circuit.