Restricted Stock Grant

It looks like my son may be getting a restricted stock grant in a foreign country. As I understand US tax law, it will be taxable in the US when it vests. But the foreign country taxes it only when it is sold. This could lead to US income tax liability in a year when it can not be offset by foreign income taxes, since the foreign taxes could be due in a future year. Is there a way to do the taxes that will not have income subject to foreign tax completely taxable in the US? Assume that form 2555 is inapplicable.

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Larry Israel
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