Focus on Tax Controversy and Litigation - June 2013

In this issue:

- Supreme Court Holds in Favor of PPL in UK Windfall Profits Case

- US District Court Rejects Talley and Permits a Business Expense Deduction for Part of Double Damages Payment Under the False Claims Act

- Tax Court Applies Step Transaction Doctrine to Corporate Reinvestment Plan, Sustains Accuracy-Related Penalties in Barnes Group v. Commissioner

- Switzerland’s Secrecy Law Cracks Under US Pressure

- IRS Announces Agreement with United Kingdom and Australia to Identify Tax Evaders

- Excerpt from: Supreme Court Holds in Favor of PPL in UK Windfall Profits Case:

The Supreme Court held unanimously in favor of taxpayer PPL Corporation in the UK windfall profits tax case, reversing a decision by the US Court of Appeals for the Third Circuit that had held that the tax was not creditable for US tax purposes under section 901.1 Rejecting the Third Circuit’s formalistic interpretation of the meaning of a creditable tax, the Court determined that the windfall profits tax was a creditable excess profits tax for purposes of the foreign tax credit because its predominant character is that of an income tax in the US sense.

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