Foreign Account Reporting: foreign tax credit calculation

I publish illustrative scenarios prepared by my practice. All participants and conversations are fictional. The fictional posts are not posts by real users, accounts of client experiences, or reports of actual results.
Illustrative scenario prepared by my practice.
For informational purposes only. This is not legal advice. Laws vary by jurisdiction. Consult a qualified attorney for advice specific to your situation.
Hypothetical question

I've been trying to resolve this on my own but I'm stuck.

foreign tax credit calculation. I've been dealing with this for about 9 months now and the situation isn't improving.

I have already consulted briefly with a lawyer but got conflicting advice.

Do I have a strong case? What should my next steps be?

Illustrative response

Just want to point out — the statute of limitations might be a factor here. In some states it's as short as 1-2 years. Don't sit on this too long.