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PPL Corp. v. CIR

On May 20, 2013, the Supreme Court issued a unanimous decision in favor of Bancroft client PPL Corporation in PPL Corp. v. CIR, 133 S. Ct. 1897 (2013). Bancroft partner Paul D. Clement argued the case on PPL’s behalf on February 20, 2013. The case involved the creditability for U.S. purposes of a U.K. windfall tax imposed on certain companies after their privatization in the 1980s and 1990s led to greater profitability than the U.K. government had anticipated. Agreeing with PPL that courts should look to the substance, not the form, of a foreign tax when determining creditability, the Court reversed the decision below and held the U.K. windfall tax creditable. This was the second unanimous victory that Bancroft secured for PPL in two consecutive Supreme Court terms. Bancroft attorneys Paul D. Clement and Erin E. Murphy prepared the briefing in both this matter and PPL Montana v. Montana.

Supreme Court Opinion
Petition for Certiorari
Brief for Petitioners
Reply Brief