@dzimmer10 , while this looks arbitrary i.e. allocation based purely on quantum of income from diff sources rather than actual amount for each source, it is a standard method applicable to all. I don't think you can over-ride this. Also note that the actual effect may or may not be that severe ( at least in most cases), because it just shifts the load and therefore may affect the allowable FTC ( even if small ), but not the total Foreign Tax Credit available.
Is there more one of us can do for you ?
