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USAco, a domestic corporation, is the wholly-owned U.S. subsidiary of FORco, a foreign corporation. The U.S.-Country F tax treaty exempts interest payments from withholding taxes.

USAco, a domestic corporation, is the wholly-owned U.S. subsidiary of FORco, a foreign corporation. The U.S.-Country F tax treaty exempts interest payments from withholding taxes. USAcos financial statements appear as follows: BALANCE SHEET Assets Liabilities & Owners Equity Cash $100 Receivables $500 Notes Payable $400 Owners Equity $200 INCOME STATEMENT Gross Income $500 Administrative Expenses $350 Interest Expense $100 The interest expense of $100 arises from a notes payable from USAco to FORco. What is the maximum amount of interest USAco may deduct on its U.S. return

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