Amcar, a U.S. corporation, had negotiated to borrow $20 million from a bank in Norway. The interest rate demanded by the bank is eight percent, net of U.S. taxes. Assume there is no tax treaty between the United States and Norway, Amcar owns a subsidiary, Partsub, established and operated in Sweden that manufactures several small parts imported into the United States for use in Amcars manufacturing operation. The Norwegian bank agrees to loan the $20 million to Partsub at a net interest of 8%. Partsub in turn loans $20 million to Amcar at 9% per annum. Assume that the U.S. Model Treaty applies between Sweden and the United States. Do U.S. withholding taxes apply to any interest payments?