So let's say that 15% of the dividend is withheld for foreign taxes. And let's say that the K1 shows that half of that is a non-taxable return of capital.
(It's been a couple weeks since I paid my taxes, I may be misremembering things) This results in the following: You cannot claim the full credit for foreign taxes paid, since the amount which you would pay in US taxes is less. There's a little math to determine how much of it you can claim as a credit. The excess gets carried over.
This would seem to imply that if / when a US owner of PGH sells (wishful thinking applies), that the carryover might be applied against the capital gains (if any)?