Wheelco, a foreign corporation, manufactures motorcycles for sale worldwide. Wheelco markets its motorcycles in the United States through Wheely, a wholly-owned U.S. sales subsidiary that derives all of its income from U.S. business operations. Wheelco also has a creditor interest in Wheely, such that Wheelys debt to equity ratio is 3 to 1, and Wheely makes annual interest payments of $60 million to Wheelco. The results from Wheelys first year of operations are as follows:

Sales ................................................................. $180 million

Interest income ..................................................... $6 million

Interest expense (paid to Wheelco) .................. ($60 million)

Depreciation expense ....................................... ($30 million)

Other operating expenses ................................. ($81 million)

Taxable income .................................................. $15 million

Assume the U.S. corporate tax rate is 35%, and that the applicable tax treaty exempts Wheelcos interest income from U.S. withholding tax. Compute Wheelys interest expense deduction.