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

Summary

The Court held that the United Kingdom’s 1997 windfall tax is creditable under 26 U.S.C. § 901(b)(1) because its predominant character is that of an excess‑profits tax, and it reversed the Third Circuit’s judgment. Justice Sotomayor, in a concurring opinion, noted a different view on outlier companies but joined the majority.