@RicN ,
1. A US person ( citizen/.GreenCard) is taxed on world income.
2. This person has a tax home in a foreign country which also taxes the person on world income.
3. In such a case and only for US purposes, US sourced passive income needs to be "resourced by treaty " to be eligible for foreign tax credit. This assumes that there is a Tax Treaty in effect at the time ( for the tax year under consideration).
Does this answer your query?
Is there more I can do for you ?
