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US Court of Appeals allows FTC for UK windfall tax

|Approved Changes|United States; United Kingdom
United States; United Kingdom

The US Court of Appeals for the Fifth Circuit has allowed a US foreign tax credit (FTC) for the windfall tax imposed in the United Kingdom. Entergy Corporation and Affiliated Subsidiaries v. Commissioner of Internal Revenue, Docket No. 10-60988 (5 June 2012). In so holding, the Court of Appeals for the Fifth Circuit has reached a decision contrary to that of the Third Circuit in a simila…

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