3-1. Stock appreciation tax

France imposes a 10 percent tax on the aggregate net appreciation in the value of stocks held by French residents at the end of a calendar year. In addition, all French residents are subject to an income tax within the meaning of reg sec 1.901-2(a). Nancy, a US citizen, lives in Paris. She buys IBM stock on 07/01/2016 for 1,000. On 12/31/2016, the stock is worth 1,100, and she pays the stock appreciation tax of 10. On 12/31/2017 the stock is worth 1,300, and she pays a stock appreciation tax of 20 (10% x 1,300 - 1,100) for 2016. She sells the stock on 1/2/2018 for 1,350 and has a gain of 350 for purposes of the French income tax. Is the stock appreciation tax a creditable tax for US tax purposes? Explain.