I checked the USA-UK treaty and got confused. It seems there is a tax credit can be applied to the UK income of the US resident. But, in the UK it is possible to combine salary and dividends from limited company in such a way that no income tax is paid up to £16,500 ($23,362) per year per person. The company pays it's corporation tax 19%. But it is not Flow-Through Entity. So, if US resident receives salary in the USA and income from limited company in the UK, it seems, although he/she has nothing to pay personally in the UK, the US tax is still payable on both salary (which will be an earned income) and dividends (15%). Correct me if I am wrong. I would be greatefull if someone could point me in right direction.