United States Third Circuit

In an appeal from a judgment of the Tax Court holding that appellee was entitled to a foreign tax credit for the 1997 tax year, judgment is reversed where appellee's liability for U.K. windfall tax is not creditable as a foreign tax under Section 901 of the Internal Revenue Code.

Appellate Information

• Decided 12/22/2011
• Published 12/22/2011

Judges

• AMBRO

Court

• United States Third Circuit

Counsel

• For Appellant:
  
• Francesca U. Tamami, Richard E. May