@pk
@pk, you input (as always!) helps. I appreciate it.
I now understand what you are saying, i.e pay full US tax and take FTC using 'passive category' for the tax portion paid in resident country OR assert the treaty using "treaty resourcing rules" and limit US tax to treaty agreed 15%. I see that most CPAs want to avoid the treaty regulations and extra forms (e.g. 8833) advocate just paying US tax and taking FTC credit in passive category.
Thanks again for your expertise.
