Now, what if a tax consultant tells Microsoft to "sell" their intellectual property to a Puerto Rican affiliate and report revenues from the sale of software as coming from Puerto Rico. Let's say Microsoft still makes $70 billion (global) profit (pre-tax) from its sale of software. Assume the US division sells all their intellectual property to Puerto Rico for $31 billion (these $31 billion must be reported as profits in the U.S., and assume the cost of producing it is still 0). Then, they claim the $70 billion as revenue to the Puerto Rican affiliate (after paying the above, making $39 billion profit in Puero Rico). The tax rate in the U.S. was 35% and the tax rate in Puerto Rico is 0%. What is the total tax that they pay now? (Please write your answer in billions of $.)