DomCo, a domestic corporation, is a wholly$-$owned subsidiary of HKco, a Hong Kong corporation. The U$.$S$.$ does not have a tax treaty with Hong Kong, but both the U$.$S$.$ and Hong Kong do have a treaty with country F that eliminates all withholding taxes. To avoid the $30\%$ withholding tax, which DomCo must withhold on all interest payments to HKco, it forms AbroadCo, a country F corporation, what will borrow the money from HKco and relend the money to DomCo?