The problem, as I understand it, is that Thailand has a completely different way of calculating "taxable income" starting from gross receipts on rental property than does the US. The US IRS has one fill out a Schedule E which can (depending on how busy you've been) reduce one's taxable income to a small fraction of the gross receipts for the year. Thailand, I've been told, is not interested in your US Schedule E; they give a standard deduction of 30% of your gross and then tax you on the resulting figure. So one could have a gross of $500,000 but still plausibly have a US "taxable income" of $50,000 depending on various circumstances, and your tax would be in the low 5 figures. But Thailand would see your taxable income as $350,000 ($500,000 minus 30%), to be taxed at 35%, resulting in a tax liability of maybe $100,000 or so after the US credit. If I'm getting this all wrong, please inform.