In 2007 my client had foreign earned income from Russia with a lot of Russina tax withheld.. As a result he has a $700 foreign tax credit carryover. It seems if he has $4,000 of earnings from France in 2008 with no taxes paid to France he is going to be able to utilize some of the carryover credit. This surprises me because it seems to be a way to get around the per country calculations. Any comments?