Etrangere, Inc., a French corporation, sold the rights to sell its product to a newly organized U.S. subsidiary, Seulement Moi, Inc., in 2019. Seulement Moi, organized on March 1, 2019, paid $650,000,000 for the exclusive right to manufacture and sell the product. Seulement Moi had sales in the U.S. of $1,250,000,000, and cost of goods sold and other expenses of $900,000,000. Those costs did not include amortization expense on the amount paid to acquire the rights to sell the product (amortizable over 180 months). How much U.S. taxable income must Etrangere recognize in 2019? Etrangere, Inc., a French corporation, sold the rights to sell its product to a newly organized U.S. subsidiary, Seulement Moi, Inc., in 2019. Seulement Moi, organized on March 1, 2019, paid $650,000,000 for the exclusive right to manufacture and sell the product. Seulement Moi had sales in the U.S. of $1,250,000,000, and cost of goods sold and other expenses of $900,000,000. Those costs did not include amortization expense on the amount paid to acquire the rights to sell the product (amortizable over 180 months). How much U.S. taxable income must Etrangere recognize in 2019