Katherine, a U.S. citizen and resident, is employed for 8 months in Country E by a Country E corporation and earns $90,000 during that period. She also owns shares of stock in several Country E corporations, which trade on the Country E stock exchange and have increased in total value by $50,000 during the current year. Under the tax laws of Country E, a taxpayers net income from all business and investment activities is subject to a tax rate of 25%. Net income from the sale of property, including stock, is subject to this tax when the property is sold or exchanged. The definition of net income for purposes of this tax is similar to the definition of taxable income in Internal Revenue Code Section 63, except that no personal deductions or form the trade or business of being an employee, gross wages are includible in income and no deductions for the expenses attributable to the wage income are allowable. In addition, the aggregate net appreciation in the fair market value of all shares of stock in Country E corporations held by a taxpayer at the end of the tax year is subject to a tax of 10%. The adjusted basis of the stock for the purposes of the 25% tax on net income is adjusted upward in an amount equal to the net appreciation in the value of the stock that was subject to this 10% stock appreciation tax. During the current year, Katherine pays the 25% tax on her compensation income and the 10% tax on the appreciation in her stock in Country E corporations. Are these Country E taxes creditable?