id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-439	Coven, Glenn E.	International Comity and the Foreign Tax Credit: Crediting Nonconforming Taxes	2022	45	.pdf	application/pdf	21962	977	57	However, the Service is evidently of the view that even if no amount of income tax is payable, a taxpayer remains subject to the income tax and thus a minimum tax can never be treated as an in lieu of' tax. On the other hand, if a strict approach to conformity is taken, one requiring the foreign law to closely resemble U.S. income tax law before crediting is allowed, then a broad approach to divisibility actually would 1999] Florida Tax Review result in substantially fewer foreign taxes becoming eligible for the credit.	cache/ftr-439.pdf	txt/ftr-439.txt