USAco a domestic corporation is the wholly-owned U.S. subsidiary of FORco a fo

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%u2019s financial statements appear as follows:

BALANCE SHEET

Assets Liabilities & Owners%u2019 Equity

Cash $100

Receivables $500

Notes Payable $400

Owner%u2019s 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?