Sun Incorporated, a U.S. corporation, owns 5,000 acres of undeveloped land in Country D, but is not engaged in business in Country D and has no income (under U.S. concepts) from Country D sources. Country D has a generally applicable tax imposed on net income at a rate of 30 percent. Under Country D tax law, an owner of real estate is deemed to realize the imputed rental value of any real estate to the extent that the imputed rental value exceeds the actual rental income (if any) received. Costs and expenses attributable to the imputed rent are allowed as a deduction in computing the base of the Country D tax. Accordingly, the 30-percent Country D tax is imposed on an imputed rental value from Sun Incorporateds land equal to $50,000 per year, less the costs and expenses attributed to the imputed rent. Is this tax creditable?