PPL Corporation & Subsidiaries v. Comr., 665 F.3d 60 (3d Cir. 2011), cert. granted, 133 S. Ct. 571(U.S. Sup. Ct. 2012)

(U.S. Supreme Court grants certiorari in case to resolve split between U.S. Circuit Courts of Appeal on issue of whether U.K. windfall profits tax paid by plaintiff’s U.K. subsidiary is creditable under I.R.C. §901; Third Circuit held that it was not and Fifth Circuit held that it was).