For over 50 years, Bloomberg Tax’s renowned flagship daily news service, Daily Tax Report® has helped leading practitioners and policymakers stay on the cutting edge of taxation and...
The U.S. Supreme Court grants certiorari to resolve a split between the U.S. Courts of Appeals for the Third and Fifth on whether the United Kingdom's windfall profits tax is a creditable foreign income tax under Internal Revenue Code Section 901. The Third Circuit, in PPL Corp. v. Commissioner, holds that a U.K. windfall tax levied against U.K. companies on a one-time basis after the privatization of British utilities and transit operators is not an “income, war profits, [or] excess profits” tax within the meaning of tax code Section 901(b)(1). Therefore, the court says, PPL Corp. was not entitled to a tax credit for the 1997 tax year, as the claimed foreign tax did not qualify for a foreign tax credit. The high court also denies the motion of petitioner Jeffrey Maehr, Docket No. 12-6169, to proceed in forma pauperis.
Notify me when updates are available (No standing order will be created).
Put me on standing order
Notify me when new releases are available (no standing order will be created)