This applies to most clients who are on the 'paid' basis for foreign tax credit purposes. For those clients on the 'accrued' basis, it can be good tax planning to time the income payments or capital transactions to take place within the start of the calendar year but before 6 April 2020. This is so that the UK tax accrues within the same US tax year for that item of income or gain, ensuring foreign tax credits are offset in the same US tax year that an item of income or gain is generated.
What should I do?
Anyone who claims the accrued basis for foreign tax credit purposes should consider timing income payments or capital transactions to take place before 6 April 2020, so that the foreign tax credit matches up with the income or gains.