UK Foreign Tax Credit Available on income received from Real Property

Dear Tax Forum:

I found Article 6 relating to real property income in the UK / USA Double Taxation Agreement.  However, from the wording, I am still unclear whether I will be able to get a UK foreign tax credit on tax already paid on real property income (e.g., from letting commercial buildings) earned in the USA.

Thank you in advance for your help.

It reads to me as if the US will tax your income because the property is situated in the US. If you are a US citizen there's another reason too. If you are taxed by the UK on your worldwide income on an arising basis, I believe you will be able to take a US tax credit for US tax paid under Article 24, relief from double taxation.


Also thanks for getting me to read something an learn a new word ------ USUFRUCT.

There is no additional benefit granted by the treaty and therefore no need to read the treaty on this as relief is given by the UK under domestic law.