The United States cedes its own taxing rights, however, only where the foreign country has the primary right to tax income. See Bowring v. Comm’r, 27 B.T.A. 449, 459 (1932) (“In the case of the citizen and resident alien, the United States recognizes the primary right of the foreign government to tax income from sources therein . . . and accordingly, grants a credit.”).Not all foreign taxes qualify for foreign tax credit treatment.