We formulate a computationally feasible method for calculating multiphoton ionization rates for atoms exposed to intense fields in the intensity regime where perturbation theory ceases to apply. The method is based on the time-independent picture of ionization, which starts with the Floquet ansatz. The question of the gauge of the radiation field is discussed in some detail. Various expressions for the ionization amplitude are derived from a variational principle, with the radiation field expressed in the velocity gauge. We consider in particular an approximation in which the wave vector developing from the initial state is replaced by a trial vector that is the Floquet expansion truncated just below the threshold for ionization, and in which the wave vector developing into the final state is replaced by a trial vector that is just the wave vector appearing in the Kroll-Watson low-frequency approximation in scattering theory. We have applied this approximation to hydrogen and we present some results for both nonresonant and resonant multiphoton ionization. We argue that the experimentally observed resonance structure in the above-threshold peaks of the ionization signal occurs through the electron jumping from one dressed-state energy-eigenvalue curve to another.