@user125562 ,
(a) Looking at US-Japan tax treaty of 2003, article 10 generally allows US recipient of dividends from a Japan entity to be taxed to be taxed by US ( in addition to Japan at its own rate ) but limits it to 10% ( for individuals and with a few restrictions as to volume of ownership etc. ). That is the maximum rate -- does not say anything about less than that.
(b) Each of the contracting states always have the option of taxing a resident/ taxpayer as if the treaty was not in existence.
(c) As you say Japan has taxed this dividend income at 15%
Thus I see no reason for you not to use the safe harbor ( i.e. without using the form 1116 and its limitations ).
Equally , while there is a requirement to report each and every earning amount, there is no requirement to report/ claim any taxes paid on that income to another taxing authority. Some may disagree with me but I stand by that.
That is my opinion on all of the above.
Is there more I can do for you ?
