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USA Logistics (a US corporation) is a wholly-owned subsidiary of EuroConnect (a foreign corporation). In the current year, USA Logistics had $99,000,000 of US taxable

USA Logistics (a US corporation) is a wholly-owned subsidiary of EuroConnect (a foreign corporation). In the current year, USA Logistics had $99,000,000 of US taxable income (all US source), calculated as follows: Gross Income 825,000,000 Deductible Royalties (all paid to EuroConnect) (350,000,000) Other deductible expenses (all paid to unrelated parties) (376,000,000) Taxable Income 99,000,000. If EuroConnect is instead located in the UK, how much BEAT will USA Logistics owe in the current year? How much total US tax will USA Logistics owe in the current year?

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