Smile Company is a domestic company engaged in manufacturing heavy machinery. Smile needs to order some specialty equipment from Churchill Company, a U.K. company which uses Libor as its functional currency. The cost of the machinery is 10,000,000 Libor.Smile signs the contract with Churchill to purchase the machinery on August 1, 2020. On that date, Smile's treasurer purchases 10,000,000 Libor for $10,000,000 when the exchange rate is 1:1. The machinery is delivered to Smile on December 1, 2020 and Smile pays Churchill 10,000,000 Libor. The exchange rate on December 1 is 1.2 Libor to $1. Describe the tax consequences to Smile of this transaction. What will Smile's U.S. tax basis be in the machinery?