My only concern is that even after re-sourcing the US based IRA distribution as per the treaty and putting it on Form 1116, it does not completely eliminate the incremental tax incurred on the distribution, thereby there remains a double taxation effect to a small degree, around 20%. Is there a way of further increasing the foreign source ratio in order to fully recover incremental tax? Perhaps it is not necessary to allocate deductions in Part I for this class of income? Any ideas? many thanks
