PPL Corp v. Commissioner of Internal Reven
Filing
AMENDED 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 wrtit of certiorari. On May 20, 2013, 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. Costs taxed in favor of Appellees., filed. Judge: THOMAS L. AMBRO, Authoring
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Case: 11-1069
Document: 003111719800
Page: 1
Date Filed: 08/26/2014
UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT
AMENDED
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
______________________ J U D G M E N T 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, 2013, 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. Costs taxed in favor of Appellees
By the Court,
s/ Thomas L. Ambro
Circuit Judge
Dated: August 26, 2014
Case: 11-1069
Document: 003111719800
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: 08/26/2014
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