Can income be deemed to be US sourced and foreign at the same time?  I have a newly arrived client from UK.  Certain vesting income is on their W2, with taxes withheld, however this income is also deemed to be UK sourced, with UK taxes withheld.  For the sake of the foreign tax credit calculation, can this income be included in Line 1 Gross income?  Without this income on Line 1, the FTC is very restricted, which seems inappropriate.

Just read about the "re-sourced by treaty" option on Form 1116, does this sound possible?