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(b) For the purposes of computing the
United States tax, the United States shall allow
as a credit against United States tax the income
tax paid or accrued to Canada after the deduction
referred to in subparagraph (a). The credit so
allowed shall not reduce that portion of the
United States tax that is deductible from
Canadian tax in accordance with subparagraph (a).
In 1986, Congress revamped the alternative minimum tax
imposed on noncorporate taxpayers. See Tax Reform Act of
1986 (TRA), Pub. L. 99-514, sec. 701(a), 100 Stat. 2085,
2320. As amended at that time, former section 55(a)
imposed an alternative minimum tax on noncorporate
taxpayers equal to the excess of the "tentative minimum
tax" over the "regular tax". The term "regular tax" was
defined to mean "the regular tax liability for the taxable
year (as defined in sec. 26(b)) reduced by the foreign tax
credit allowable under section 27(a)". Sec. 55(c)(1).
Former section 55(b) defined "tentative minimum tax" as an
amount equal to 21 percent of so much of the "alternative
minimum taxable income" for the taxable year as exceeded
the "exemption amount", reduced by the "alternative minimum
tax foreign tax credit" for the year. Former section
59(a)(1) defined "alternative minimum tax foreign tax
credit" as the foreign tax credit allowed by section 27,
with certain adjustments that we need not detail here, and
former section 59(a)(2)(A), the predecessor of the
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