Should I make the election to treat foreign losses as allowable?

My wife and I each have until 5th April to choose whether or not to make an election to treat foreign losses as allowable for UK purposes, as described here: http://www.hmrc.gov.uk/manuals/rdrmmanual/rdrm32060.htm

We're both US citizens, and aside from our UK employer pensions, we expect all our future investing to be exclusively in the US for all the usual reasons. So we will never have UK losses, only foreign ones. I can see us benefiting from being able to use foreign losses to offset foreign gains, which UK law does not allow unless an election is made.

For this reason I was leaning towards making the election, but as it is irrevocable, I thought I'd better be quite careful. Has anyone had to make this choice before?

This is an excellent point as the 16ZA election is frequently missed entirely.  There was extensive discussion in the professional press during 2008 and 2009 for anyone who wishes to research more deeply.

So it looks as if broadly speaking the professionals recommend that someone whose assets are entirely abroad should make the election.

However, interestingly I came across this language from HMRC:

With the exception of individuals who may use the remittance basis under ITA07/s809D or s809E without claim (refer to RDRM32100 Exceptions to the claim requirements), non-domiciled remittance basis users are required to make an election under TCGA1992/s16ZA if they want their overseas losses to be offset against foreign chargeable gains.

My unremitted foreign income has been under the £2000 threshold each and every year so it would appear I am covered as an individual who may use the remittance basis under s809D without claim. In this case, I'd only have to make the election for the first tax year in which I both claim the remittance basis and report unremitted foreign income over £2000.

The one complication is that I did file SA returns for 2011-12 and 2012-13, but for reasons other than claiming the remittance basis. I did of course fill in the remittance basis pages and tick the box for foreign income under £2000. I'd be interested in knowing whether such an SA return constitutes a "claim" to the remittance basis and therefore I'd need to make the election for the first year where a return was filed. Any views are appreciated.