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Business, 01.10.2019 05:30 nathanbrockdac

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 nancy, france. she buys ibm stock on july 1, 2017 for €1,000. on 12/31/2017, the stock is worth €1,100, and she pays the stock appreciation tax of €10. on 12/31/2018 the stock is worth €1,300, and she pays a stock appreciation tax of €20 (10% x 1,300 - 1,100) for 2018. she sells the stock on 1/2/2019 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.

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