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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...

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