Supreme Court Mulls PPL's Bid For $39M Credit Over UK Tax

Law360, New York (February 20, 2013, 7:25 PM EST) -- The U.S. Supreme Court seemed split during oral arguments Wednesday over utility PPL Corp.'s contention that it's entitled to $39 million in U.S. Internal Revenue Service tax credits for tax paid by a British subsidiary.

PPL argues that a “windfall” tax paid by South Western Electricity PLC — a U.K.-based utility it partly owns — qualifies for an IRS foreign tax credit because it constituted an excess profits tax and thus an income tax. The government claims that the windfall tax was based on the company's...
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