- 15 - 1986 and was made effective as if it had been included therein. TAMRA sec. 1012(aa)(4), 102 Stat. 3532. Thus, the Third Protocol specifically takes into account, as the taxes to which the convention shall apply, the alternative minimum tax as amended by the Tax Reform Act of 1986, including the limitation on the alternative minimum tax foreign tax credit imposed by section 59(a)(2). Accordingly, we find that there is harmony between provisions of the U.S.-Canada treaty and section 59. Pekar v. Commissioner, supra at 163; Brooke v. Commissioner, T.C. Memo. 2000-194. In light of the above, it is unnecessary to address the second element of petitioners' position, that the U.S.-Canada treaty was the last expression of sovereign will. Since we find no conflict between the U.S.-Canada treaty and section 59(a)(2), petitioners are subject to section 59(a)(2), regardless which is later in time. We have considered all the other arguments made by petitioners, and, to the extent we have not addressed them, find them to be without merit. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
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