According to IRS p970 instructions,
Completion of first 4 years. A student has completed the first 4 years of postsecondary education if the institution at which the student is enrolled awards the student 4 years of academic credit at that institution for coursework completed by the student before 2023. This student generally wouldn't be an eligible student for purposes of the American opportunity credit."
So if attending a qualified institution in the UK, the student is awarded 3 years of academic credit to get a degree. And the exception hasnt occurred, so it would therefore allow the first year of postgraduate schooling to be eligible for the AOTC.
Sounds like this is a situation that they did not consider writing the rules; I would think if they decided to Audit that the IRS would lose.
