I think you're missing something, slim_slag. Part 97 describes only approaches to airports in the US. By your interpretation, an N-reg aircraft could never fly an IAP outside the US.
You also misconstrue 91.169(c)(2). 91.169(c) sets out the requirement for filing an alternate airport. 91.169(c)(2) set out the conditions under which an airport without IAP may be used to meet those requirements.
That said, given the airspace structure differences, I don't think the FAA would be nearly as flexible in interpreting the minimum altitude rule in regard to IAPs in the US as the CAA have to be in the UK.