Sourcing of income (Capital gains) - Form 1116

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Hi.

My client is a US citizen and he has been residing in Korea for over 5 years. His family lives in Korea and he has the permanent residence in Korea.

He works for a Korean branch of multinational corporation and receives RSUs from the US branch every year. He has also sold RSUs through a US investment company.

I understand that the salary and RSUs he receives while working in Korea is given priority to taxation in Korea. However, I am curious to which country is the first to be taxed by RSUs sold in the United States.

Because he paid taxes on the profits of selling RSUs in Korea before reporting to the US, I wonder if this tax can be used as a foreign tax credit when filing to the US.

According to my research so far (Section 861, 862, 863, 865), since the income is from the United States, unlike salary, I think it is correct to pay taxes to the United States first and apply foreign tax credit to Korea.

Has anyone handled this situation? I need your opinion.

Thank you.