Use of Extrinsic Evidence and Quantitative Analysis in PPL Corp. v. Comm'r

Despite the quantity of ink spilled by the Tax Court in its lengthy review of the factors which govern a creditable foreign income tax, the key takeaway for corporate tax counsel and their advisors from PPL Corp. & Subsidiaries v. Comm'r , 2010 U.S. Tax Ct. LEXIS 31 (T.C. Sept. 9, 2010) is the...