PPL Corporation and Subsidiaries v. Commissioner of Internal Revenue - Post-Decision SCOTUScast
SCOTUScast 6-10-13 featuring Christina Sandefur
On May 20, 2013, the Supreme Court announced its decision in PPL Corporation and Subsidiaries v. Commissioner of Internal Revenue. The case considered 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.
In an opinion delivered by Justice Thomas, the Court held unanimously that the foreign tax was creditable against federal income taxes. Justice Sotomayor filed a concurring opinion.
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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