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. O $0 O $4,000,000 O $21,000,000 O $25,000,000 O None of the above