The US Tax Court has held that the 90% foreign tax credit (FTC) limitation on the alternative minimum tax (AMT) contained in Section 59 of the US Internal Revenue Code (IRC) prevails over the requirement in the 1980 US_Canada tax treaty to eliminate double taxation. William D. and Judith A. Jamieson v. Commissioner of Internal Revenue, Docket No. 16421-05 (29 April 2008). The taxpayers were US citizens who resided in Canada in 2003. In filing their US income tax return, they took the position that their liability for the US AMT was fully offset by a credit for income taxes...