I’m not sure it’s as easy as you say Dave. I am a Canadian citizen and also a USA citizen and now an Italian citizen who moved to Italy in 2024 and became a tax resident there. Regarding my Canadian bank sourced income and also my USA bank sourced income, I am not sure that they can both be considered as “re-sourced by treaty” on Form 1116. While I know for certain that the USA sourced interest income has to be re-sourced in order to be able to get a ftc for the Italian tax paid on that same USA sourced interest income, I am not sure that the Canadian sourced interest income is treated exactly the same way. Isn’t the Canadian bank sourced income considered on a separate Form 1116 and “passive income”. That is what I was asking about. I pay no tax in Canada as taxation there is based strictly upon residency, not citizenship, and I haven’t resided there since 1990 when I moved to the USA. I moved to Italy in 2024 where I procured my citizenship and also became a tax resident.
