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Prescott Pharmaceuticals, a U.S.-based taxpayer, is a wholly owned subsidiary of an Austrian pharmaceutical company. Prescott pays royalties and interest expense to its Austrian parent.

Prescott Pharmaceuticals, a U.S.-based taxpayer, is a wholly owned subsidiary of an Austrian pharmaceutical company. Prescott pays royalties and interest expense to its Austrian parent. Prescotts U.S. taxable income for the current year appears below (amounts are in millions of U.S. dollars):

Revenues $720
Cost of goods sold 156
Research and development expense 123
Salaries expense 121
Other operating expense 48
Royalties 98
Interest expense 54
Taxable income $120

Prescott conducts its research and development activities in the U.S. and pays salaries to U.S. employees at five locations around the country. Prescott incurs other operating expenses within the U.S. Prescott has generated more than $500 million in revenues in each of its fifteen years of operation. The U.S. corporate tax rate is 21 percent.

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Determine the amount of base erosion anti-abuse tax (BEAT), if any, that Prescott owes in the current year.

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