On this edition, Elizabeth Sweigart and Lynn Loden discuss the distinctive aspects of the U.S. Tax Court's recent decision in PPL Corporation & Subsidiaries v. Commissioner and the holding's potential impact on uncertain tax position reporting preparation. Ms. Sweigart and Mr. Loden examine the use of extrinsic evidence in determining the "predominant character" of a "windfall tax" imposed by the United Kingdom. They explain the key role extrinsic evidence played in the court's conclusion that the "windfall tax" was indeed creditable as an income tax under IRC § 901 and accompanying Treas. Reg. § 1.901-2(a)(3). Copyright© 2010 LexisNexis, a division of Reed Elsevier Inc.
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Interviewees Elizabeth Sweigart and Lynn Loden are Directors at Opportune LLP.
View commentary analysis of PPL Corp. v. Comm'r. on this site by Lynn Loden, Elizabeth Sweigart and Alyssa Quiballo
View an opinion summary free on this site of PPL Corp. & Subsidiaries v. Comm'r, 2010 U.S. Tax Ct. LEXIS 31 (T.C. Sept. 9, 2010)
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