I came to the UK midway through 2009 and because I didn't pay much UK tax in 2009, I elected to use the foreign earned income exclusion covering the second half of the year, as that seemed the better option at the time.
Now it turns out that I paid significantly more UK tax in 2010 and so I would have owed less on my 2009 return if I had claimed the foreign tax credit and then carried back the excess foreign tax credit from my 2010 return.
It looks like the IRS guidance is that once you take the exclusion you can't just go back and amend your return. You have to officially revoke your choice and then if you want to take it for a future tax year (which I do) you have to request a ruling from the IRS.
Has anyone done this before or been in a similar situation? Thanks for your input.
