Ppl Corporation and Subsidiaries, Petitioners v. Commissioner of Internal Revenue.

Summary

The Supreme Court held that the United Kingdom’s 1997 windfall tax is creditable under IRC §901(b)(1) as an excess‑profits tax, reversing the Third Circuit’s judgment. Justice Sotomayor filed a concurring opinion noting that if outlier companies were considered, the tax might be characterized as a tax on value rather than income.