My wife is a US Citizen but originally from Thailand. She has many investments there and we are trying to evaluate some Dividends as to whether they meet the test. The most important one is some Dividends she received from her stock in Sept 2017. The stock is from Company which harvests and produces rubber. Her father was part owner. He passed away and these stocks were put in her name around Apr 2017. She also had taxes deducted from the DIV payment. She has not sold any of the stock. And it is not publicly traded on the Thai Stock Market. As near as I can tell, this transaction qualifies as a Qualified Dividend according to the criteria specified in the “1099DIV” instructions: Qualified foreign corporation. A foreign corporation is a qualified foreign corporation if it is: 1. Incorporated in a possession of the United States, or 2. Eligible for benefits of a comprehensive income tax treaty with the United States that the Treasury Department determines is satisfactory for this purpose and that includes an exchange of information program. Whereby Thailand is included in the list of countries with an existing treaty. So, is it Qualified or not? And, if so, it should also qualify as a foreign tax credit, correct?
There is the issue that she might be a "controlled foreign corporation shareholder." (CFC). See Pub 514 for more info on this issue.
Thailand is on the qualified list, so I'd say the dividends are qualified.