Abstract

http://ssrn.com/abstract=2222423
 


 



Explanation of Issues in PPL Corporation v. Commissioner of Internal Revenue


Jordan M. Barry


University of San Diego School of Law

Janelle N. Darnell


University of San Diego School of Law

February 19, 2013

American Bar Association Preview of United States Supreme Court Cases, Vol. 40, Issue 5, pp. 201-04, 2013

Abstract:     
This short article briefly summarizes the chief arguments of PPL corporation and the IRS as to whether the United Kingdom's Windfall Tax qualifies for a United States foreign income tax credit under 26 U.S.C. § 901. PPL argues that the Windfall Tax is a tax on income and that PPL is therefore entitled to a foreign tax credit that will greatly reduce its federal income tax liability. The IRS argues that the Windfall Tax is a tax on value and, accordingly, that PPL is not entitled to a foreign tax credit. This case could have major implications for U.S. corporations, which claim over $100 billion in foreign tax credits each year.

Number of Pages in PDF File: 4

Keywords: tax, international tax, corporate tax, foreign tax credits, PPL, Entergy, income tax, value tax, Section 901, Section 902, deferral, territoriality, worldwide taxation, double taxation, windfall tax, privatization, privatisation, utilities, utilities regulation, energy taxation, valuation

JEL Classification: H20, H25, H29, K34

Accepted Paper Series


Download This Paper

Date posted: February 26, 2013  

Suggested Citation

Barry, Jordan M. and Darnell, Janelle N., Explanation of Issues in PPL Corporation v. Commissioner of Internal Revenue (February 19, 2013). American Bar Association Preview of United States Supreme Court Cases, Vol. 40, Issue 5, pp. 201-04, 2013 . Available at SSRN: http://ssrn.com/abstract=2222423

Contact Information

Jordan Barry (Contact Author)
University of San Diego School of Law ( email )
5998 Alcala Park
San Diego, CA 92110-2492
United States
Janelle N. Darnell
University of San Diego School of Law ( email )
5998 Alcala Park
San Diego, CA 92110-2492
United States
Feedback to SSRN


Paper statistics
Abstract Views: 446
Downloads: 114
Download Rank: 142,587
People who downloaded this paper also downloaded:
1. Top 10 Tips for a Newly Tenured Professor
By Eric Goldman

© 2014 Social Science Electronic Publishing, Inc. All Rights Reserved.  FAQ   Terms of Use   Privacy Policy   Copyright   Contact Us
This page was processed by apollo8 in 0.297 seconds