Furthermore, there is a very nasty catch in the ATM. There is a special clause in the instructions that requires you to fill out the ATM form, but filling it out in a different way than specified in the instructions. It's incredibly confusing, but it looks like you compute the ATM without the foreign tax credit, and then divide the result by 10. So  if all your income is from abroad, some of it will be taxed at 2.6%, even if you are living in a country that taxes that income at over 97.4%.