USCo, a wholly owned U.S. subsidiary of ForCo, a foreign corporation. USCo generated average annual gross receipts of $700,000,000 for the last three years. In 2018, USCo had $100,000,000 taxable income from $600,000,000 gross receipts. Included in USCo's $500,000,000 deductions was a $400,000,000 royalty payment to ForCo. ForCo is incorporated in a tax haven. How much is USCo base erosion anti-abuse tax for 2018.

Group of answer choices

$0

$4,000,000

$21,000,000

$25,000,000

None of the above.