iain MacDonnell

Hi, Thanks, but unfortunately I cannot find a clear answer to my specific questions in the documentation. My questions are: 1) If I had income from two different companies *in the same foreign country*, does that count as *one item* or *two items* when calculating FTCR? 2) If the second company was administering leave for employment under the first company, can that be considered a single source of income (employment)?

I have what I think is a slightly unusual foreign tax credit situation... I am a UK citizen. I had been living, and working, in California, on a green card. In June 2021, I needed to return to the UK due to a family medical situation. I was considering it temporary at the time. My employer allowed me to work in the UK for 90 days, after which I went on California Paid Family Leave for 8 weeks, then unpaid leave. I ended up deciding to stay in the UK permanently, and resigned from the company. I had no further income in the UK 2021/22 tax year. I filed a tax return in the US for the 2021 year, including income tax on my employment and leave (it was withheld anyway). I'm now working with a UK accountant on my UK return for the 2021/22 year, and trying to minimise double-taxation. He has decided to apply a split-year strategy, so we're looking at income from my date of entry to the UK (June) onwards. The issue I'm running into is that my paid leave was administered by, and paid by, a third party company (The Hartford). I got a separate W2 for it, and it appears as if it was a second employer on my US tax return. My UK accountant is saying that he therefore has to treat my salary and my leave as two separate income "items", and calculate foreign tax credit on each. This can be done in either order, and one does result in less tax owed than the other, but in both cases, one of the income items results in the UK equivalent tax being less than what I paid in the US (mostly due to my personal allowance) and the other more - but I can only claim relief on the smaller number, so I end up owing some UK tax. If I was able to combine the salary and leave as a single income item, it would result in my UK equivalent tax being almost exactly the same as what I paid in the US, so minimal UK tax due... but my accountant is saying that they cannot be combined, because they show up as two items on my US tax return. So I have a couple of questions: * Would income from multiple sources (e.g. two different employers) in the same foreign country normally be treated as seperate items for FTCR? * Given that my paid leave was an entitlement under my employment with the original company, and not a separate employment, could I make the argument that this was all one source of income? (I'd have to make this argument to HMRC, if they called me out on it) It seems that this situation could also apply to an employee of a company that got acquired by another company during the year for which they're requesting FTCR. I wonder if anyone has run into such a situation? TIA for any guidance....