JUDGMENT ORDER

By Opinion and Judgment entered December 22, 2011, this Court held that the United Kingdom windfall tax is not creditable foreign tax under Internal Revenue Code § 901 and reversed the decision of the Tax Court.

By order dated October 29, 2012, the Supreme Court of the United States granted PPL Corporation’s petition for writ of certiorari. On May 20, 2013, the Supreme Court issued its opinion reversing the judgment of this Court.

Accordingly, it is hereby ORDERED that the judgment of the Tax Court is hereby affirmed. Costs taxed in favor of Appellees