Roth 401(K) and Foreign Tax Credit

[James CFP]

Here is an interesting one to discuss:

We have a client (gov't contractor) who has a large workforce outside of the U.S.. None of these pay U.S. tax due to their claiming of the Foreign Tax Credit.

Would these U.S. nationals working abroad (an not paying U.S. tax) be able to participate in the company's Roth 401(k) program? (None want to participate in the reg. 401(k) as they feel like they will be taxed twice.)'

Thanks,

James