How the Supreme Court’s decision in the PPL dispute could influence debate on US territorial tax system

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

How the Supreme Court’s decision in the PPL dispute could influence debate on US territorial tax system

Joe Dalton
February 21 2013
ppl-small.jpg

PPL Corporation (PPL) kicked off its appeal over the creditability of UK windfall tax for US foreign tax credit purposes in the US Supreme Court yesterday. If the judgment causes uncertainty about which foreign taxes are creditable in America it could affect the way US taxpayers invest abroad.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

NewsUnited StatesUnited KingdomTax DisputesEurope
JD
Joe Dalton
Contact
Joe Dalton worked at ITR between 2011 and 2013
more across site & shared bottom lb ros

More from across our site

Direct Tax
hmrc.jpg
A taxing week: Welcome change ahead for UK tax adviser requirements
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Sam Sholli, May 15 2026
Direct Tax
netherlands
This week in tax: Greenberg Traurig loses case over faulty tax advice to Dutch DJ
Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
Sam Sholli, May 15 2026
Transfer Pricing
Brazil.jpg
‘TP not a mechanical compliance exercise’: experts dissect Brazil’s Petrobras ruling
The case sits within a context of Brazil signalling that it is replacing informal discretion and ambiguity with structures that reward analytical rigour, one expert tells ITR
Sam Sholli, May 14 2026
Podcasts
Taxing Times podcast Jeff Soar WTS article header
Podcast: WTS UK’s CEO breaks cover on strategy, the big four and AI
Jeff Soar lifts the lid on WTS UK’s ambitious recruitment plans, the firm's positioning against the big four, and why tax is the perfect profession for AI
Tom Baker, May 14 2026
Direct Tax
Rampulla.png
Charles Russell appoints partner to build Italian corporate tax practice
The move reinforces Milan’s role as a key European hub for international business, the firm said
Sam Sholli, May 13 2026
Direct Tax
New York, USA - 29 September 2020: Australian Government Taxation Office ato.gov.au company website with logo close up, Illustrative Editorial
ATO to receive A$86.3m funding over four years
Australia’s government has also announced that it will implement the pillar two side-by-side agreement
Sam Sholli, May 13 2026
Direct Tax
London
Exclusive: Fieldfisher private client specialist leaves for barrister-led practice
Sara Morgan is due to join Joseph Hage Aaronson & Bremen as a partner in London, ITR understands
Tom Baker, May 11 2026
Direct Tax
alex jupp tim shuman.png
‘No one’s eating anyone else’s lunch’: inside McDermott’s tax-powered merger
The newly combined tax team has already worked on thousands of joint client matters, leaders from McDermott Will & Schulte tell ITR
Tom Baker, May 11 2026
AI in tax forum 2026 crowd shot
A taxing week: 2026 is the watershed year for AI in tax
As AI becomes increasingly intuitive and idiot-proof, its tax applicability is becoming impossible to overstate
Tom Baker, May 08 2026
Direct Tax
The globe, with lines connecting different countries
This week in tax: US and Swiss MNEs lag global counterparts on CbCR compliance
New data on public CbCR showed uneven adoption, as Singapore advanced pillar two compliance and firms expanded their tax capabilities
Tom Baker, May 08 2026
Gift this article