Unresolved Issues Regarding the U.S. Foreign Tax Credit: A Case of the United Kingdom Windfall Tax

ABSTRACT

In May 2013, the U.S. Supreme Court decided PPL Corp. & Subsidiaries v. Comm'r to resolve a split between the Third and Fifth Circuit Courts of Appeals regarding whether the U.K. windfall tax constitutes a creditable tax under Internal Revenue Code (IRC) Section 901. The results of this case have policy implications reaching far beyond a one-time foreign tax credit of $488 million for ...more