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This paper is NOT THE PUBLISHED VERSION; but the author's final, peer-reviewed manuscript. The published version may be accessed by following the link in th citation below.

§ 222(a)(1) provided a foreign tax credit for individuals, § 238(a) provided a similar credit for domestic corporations, and § 240(c) described creditable taxes). The British had previously allowed foreign tax credits for taxes paid within the British Commonwealth. See Thomas S. Adams, Interstate and International Double Taxation, in LEcru.ES ON TAXATION 101, 102 (Roswell Magill ed., 1932) [hereinafter Adams, Double Taxation]. The Revenue Act of 1918 also adopted the so-called indirect foreign tax credit, which allows U.S. companies a tax credit for foreign taxes paid by their controlled foreign subsidiaries. See infra note 100 and accompanying text.

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