In 2021, Fendrich Inc. (a U.S. taxpayer) generated revenues of $600 million and incurred tax-deductible expenses of $480 million, resulting in U.S. taxable income of $120 million. Expenses include royalty payments and other base erosion payments, made to their offshore subsidiary FendBarb, amounting to $150 million. The Fendrich group as a whole averages more than $500 million revenue per year. In 2021, FendBarb (in Barbados) had QBAI of $100 million and recognized $225 million revenue with $130 million in operating expenses. FendBarb's average corporate income tax rate is 2.5%. FendBarb was created as a wholly owned subsidiary in 2001 in Barbados. FendBarb has reported accumulated pre-tax earnings for the period 2001-2017 at $2,800 million. Accumulated pre-tax earnings allocated to the "held in cash" category is $2,000 million. None of the earnings generated by FendBarb have been repatriated back to Fendrich Inc. Although a portion of income generated by FendBarb is passive income, it has managed to avoid being treated as subpart F income. Any tax liability resulting from the DRAFE provision will be paid over tzhe allowable 8-year period. Determine the amount of 2021 U.S. income tax liability for Fendrich U.S. regular income tax and the BEAT DRAFE, and GILTI provisions of the 2017 TCJA. Be sure to provide supporting calculations and analysis. Record your answers below: TCJA Provision Regular US Income tax BEAT GILTI DRAFE TOTAL Net 2021 U.S. Tax Liability (after applicable FTC) $x.xxx (million) $31.5 million