Our family returned to Ireland after being in the States for a decade. My wife is American and my son and I are dual citizens. Every tax year, we now submit two tax returns in the US and Ireland. We were tax residents of Ireland for 2019, but not domiciled or ordinary residents because of the nature of my work. We earned deposit interest on some savings we had from the sale of our primary residence in the States in 2019. The deposit interest remains in the US and has not been brought into Ireland. Because of the tax treaty between the US and Ireland, there was no tax liability for this deposit interest because of the foreign tax credit (Irish taxes were much higher than what would be paid in the US for the same income).
My question is, because of our tax status, is this US deposit interest liable for tax or would it qualify under the remittance basis of taxation claim?