Foreign field

I have a client who has owned a foreign property since 2006. He started to let it as holiday accommodation in 2009 and so far has only made losses although he reckons he has let it for at least 70 days a year.

Our client has no other foreign income for 2009/10 or 2010/11.

What we would like clarification on are the implications of making or not making the choice offered in the tax return of treating this as furnished holiday letting.

As the sideways loss relief has gone in any case from 6 April 2011 and as our client has no income that he can set this loss against in 2009/10 or 2010/11 (unless I have misunderstood and the relief is more generous) does the choice make any income tax difference?

Finally will our client...