4. Wheelco, a foreign corporation, manufactures motorcycles for sale worldwide. Wheelco markets its motorcycles in the United States through Wheely, a wholly-owned U.S. marketing subsidiary that derives all of its income from U.S. business operations. Wheelco also has a creditor interest in Wheely, such that Wheelys debt to equity ratio is 3 to 1, and Wheely makes annual interest payments of $60 million to Wheelco. The results from Wheelys first year of operations are as follows: Sales ............................................................................................. $180 million Interest income ............................................................................... $6 million Interest expense (paid to Wheelco)................................................................................................. $60 million Depreciation expense....................................... .............................. ($30 million) Other operating expenses................................. .............................. ($81 million) Pre-tax income ................................................. ............................ $15 million Assume the U.S. corporate tax rate is 35%, and that the applicable tax treaty exempts Wheelcos interest income from U.S. withholding tax. Compute Wheelys interest expense deduction