Mitchell Kane files amicus brief in US Supreme Court foreign tax credit case, PPL Corp. v. Comm’r. Erin Scharff (’11) is counsel of record.
Mitchell Kane, Professor of Law, has co-authored an amicus brief in PPL Corp. v. Commissioner, Docket No. 12-43. Erin Scharff, Acting Assistant Professor of Tax Law, was the counsel of record on the brief. The U.S. Supreme Court will hear oral arguments in the case on February 20th. The issue presented is “Whether, in determining the creditability of a foreign tax, courts should employ a formalistic approach that looks solely at the form of the foreign tax statute and ignores how the tax actually operates, or should employ a substance-based approach that considers factors such as the practical operation and intended effect of the foreign tax.” A copy of the brief is available here.