Ken Limited $($Ken$)$ is a foreign corporation that manufactures widgets and resides in Country Y$.$ Ken also manufactures widgets in the United States through a U$.$S$.$ limited liability company that is treated as a domestic disregarded entity for U$.$S$.$ tax purposes $$ i$.$e$.,$ a U$.$S$.$ branch of Ken. During the current tax year, the U$.$S$.$ branch of Ken had effectively connected earnings & profits $($E&P$)$ of $$3,000,000,$ and its U$.$S$.$ net equity was $$1,200,000$ at the beginning of the year and $$1,700,000$ at the end of the year.

Ken$$s total worldwide liabilities, including U$.$S$.$ booked liabilities, were $$9,000,000$ on which it had paid interest of $$270,000$ to a bank in Country Y$,$ while Ken$$s U$.$S$.$ booked liabilities were $$3,000,000$ on which it had paid interest of $$90,000$ to a bank in Country Y$.$

During the year, the value of Ken$$s U$.$S$.$ assets producing effectively connected income were $$4,000,000,$ while the value of Ken$$s worldwide assets, including U$.$S$.$ assets, were $$24,000,000.$

$($a$.)$ For U$.$S$.$ tax purposes, compute the U$.$S$.$ branch$$s dividend equivalent amount and branch profit tax for the current tax year. Assume that the United States does not have a bilateral income tax treaty with Country Y$.$

$($b$.)$ For U$.$S$.$ tax purposes, what is the maximum interest expense deduction that may be taken by the U$.$S$.$ branch for the current tax year? Does the payment or deduction of interest expense by the U$.$S$.$ branch trigger a U$.$S$.$ tax liability? If so$,$ please identify the type of tax and the amount of tax triggered. Again, assume that the United States does not have a bilateral income tax treaty with Country Y$.$