PPL Corp v. Commissioner of Internal Reven

Filing

Judgment Order (AMBRO, CHAGARES and GARTH, Circuit Judges) By Opinion and Judgment entered December 22, 2011, this Court held that the United Kingdom windfall tax is not creditable foreign tax under Internal Revenue Code 901 and reversed the decision of the Tax Court. By order dated October 29, 2012, the Supreme Court of the United States granted PPL Corporation 's petition for writ of certiorari. On May 20, 2014. the Supreme Court issued its opinion reversing the judgment of this Court. Accordingly, it is hereby ORDERED that the judgment of the Tax Court is hereby affirmed., filed. Judge: THOMAS L. AMBRO, Authoring

Case: 11-1069

Document: 003111715577

Page: 1

Date Filed: 08/21/2014

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT
No. 11-1069
PPL CORPORATION AND SUBSIDIARIES
v.
COMMISSIONER OF INTERNAL REVENUE,
Appellant
_________________
Appeal from Decision of the
United States Tax Court
Tax Court Docket No. 07-25393
Tax Court Judge: Honorable James S. Halpern
_________________

Present:

AMBRO, CHAGARES and GARTH, Circuit Judges

_______________________________ O R D E R ______________________________
By Opinion and Judgment entered December 22, 2011, this Court held that the United
Kingdom windfall tax is not creditable foreign tax under Internal Revenue Code §901
and reversed the decision of the Tax Court.
By order dated October 29, 2012, the Supreme Court of the United States granted PPL
Corporation’s petition for writ of certiorari. On May 20, 2014, the Supreme Court issued
its opinion reversing the judgment of this Court.
Accordingly, it is hereby ORDERED that the judgment of the Tax Court is hereby
affirmed.
By the Court,
/s/ Thomas L. Ambro, Circuit Judge
Dated: August 21, 2014

Case: 11-1069

Document: 003111715577

Appeal No. 11-1069
PPL Corp v. Commissioner of Internal Revenue
Page 2

DWB/cc:
Mark B, Bierbower, Esq.
Timothy L. Jacobs, Esq.
Richard E. May, Esq.
Thomas J. Clark, Esq.
Gilbert S. Rothenberg, Esq.
Francesca U. Tamami, Esq.
Alan I. Horowitz, Esq.
John A. Nolet, Esq.
Francesca Ugolini, Esq.

Page: 2

Date Filed: 08/21/2014