are entitled to a foreign tax credit for their share of foreign income taxes paid by an S corporation. See I.R.C. §§ 901(b)(3), 1373(b) (1986). Vermont’s tax provisions contain no language expressly denying taxpayers the credit at issue. In light of Vermont’s § 5820 policy conforming our tax code to the I.R.C., absent an express provision to deviate from the federal tax scheme, like the newly enacted § 5916, shareholders are entitled to a tax credit for their share of “foreign” income taxes paid by an S corporation in another state, regardless of whether that “foreign” state recognizes S corporations. See White v. Commissioner, No. 6558, 1995 WL 495912, at *2 (Minn. T.C., Aug. 18, 1995); In re Baker, No. 805550 TSB-D-90(28)I, 1990 WL 169491, at *3 (N.Y. Tax App. Trib. Oct. 11, 1990) (<HOLDING>). While the federal legislation concerning S
holding that claims of corporation vest in corporation holding that corporation and sole owner of corporation were separate legal entities and corporation was not party to contract signed by owner in individual capacity holding that interest received by a foreign corporation on a tax refund from the united states was interest on an interestbearing obligation of a resident of the united states within income tax statute holding that resident shareholder of s corporation is eligible for tax credit for taxes paid by corporation in another state and noting that this conclusion is consistent with the internal revenue code which provides that shareholders of an s corporation are entitled to a foreign tax credit for their share of foreign income tax paid by an s corporation holding that a corporation exists as an entity apart from its shareholders even where the corporation has but one shareholder the general proposition of corporate identity apart from its shareholders leads us to conclude in accordance with decisions from other jurisdictions that the attorneys client is the corporation and not the shareholders