USA Is there a US tax on dividends received from UK corporation by US resident?


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The corporation owner is a British citizen living in the US as a permanent resident (green card holder). Having reading the UNITED STATES-UNITED KINGDOM INCOME TAX CONVENTION, I got confused by Article 10 Dividends. The convention entered into force in 1980... Back in 2016 UK has abolished Tax Credit on dividends. So, tax free dividends, potentially availiable to the UK corporation owner in the UK, are £5,000 ($7,000) and up to £16,500 ($23,000) per year - depending on individual circumstances. Therefore, it is not clear which, if any, tax credit, is availible to the tax payer in the US? Or will these dividendsl be taxed by IRS as normal income? The corporation is not a listed corporation.
 
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