PPL Corp v. Commissioner of Internal Reven, No. 11-1069 (3d Cir. 2014)
Annotate this CaseThis opinion or order relates to an opinion or order originally issued on December 22, 2011.
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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 ยง901 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 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.
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