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 the allowable 8-year period. Determine the amount of 2021 U.S. income tax liability for Fendrich U.S. regular income tax and the and GILTI provisions of the 2017 TCJA. BEAT D Be sure ovide supporting calculations and analysis. Record your answers below: TCJA Provision Net 2021 U.S. Tax Liability (after applicable FTC) $x.xxx (million) Regular US Income tax BEAT GILTI DRAFE TOTAL