Wheelco, a foreign corporation, manufactures motorcycles for sale worldwide. Wheelco markets its motorcycles in the United States through Wheely, a wholly-owned U.S. marketing subsidiary that derives all of its income from U.S. business operations. Wheelco also has a creditor interest in Wheely, such that Wheely%u2019s debt to equity ratio is 3 to 1, and Wheely makes annual interest payments of $60 million to Wheelco. The results from Wheely%u2019s first year of operations are as follows:

• Sales.. $180 million
• Interest income. $6 million
• Interest expense (paid to Wheelco). $6 million
• Depreciation expense.. ($30 million)
• Other operating expenses.. ($81 million)
• Pre-tax income.. $15 million

Assume the U.S. corporate tax rate is 35%, and that the applicable tax treaty exempts Wheelco%u2019s interest income from U.S. withholding tax. Compute Wheely%u2019s interest expense deduction.