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On February 20, 2013, the Supreme Court heard oral argument in PPL Corporation and Subsidiaries v. Commissioner of Internal Revenue. The case considers whether, in determining the “creditability” of a foreign tax--meaning the extent to which a U.S. company paying the foreign tax can claim a corresponding credit against its U.S. taxes--courts can and should take account of the practical operation and intended effect of the foreign tax.

To discuss the case, we have Christina Sandefur, who is a staff attorney at the Goldwater Institute’s Scharf-Norton Center for Constitutional Litigation.

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