Isn’t the whole purpose of Form 1116 and the box that can be ticked to indicate that some income is being re-sourced from the USA to Italy to inform the irs of what you are doing in accessing the FTC because you are paying tax on that same income to a foreign country and need to offset the USA tax on that same income? In other words, why would form 1116 have a box to tick indicating the re-sourcing of income under a tax treaty if you also had to complete a form 8833? I believe that there are situations where you do not have to complete a form 8833 and I believe that my situation is one of them.
