Rio Limited $("$Rio$")$ is a foreign corporation that manufactures widgets and resides in Country Y$.$ Rio also manufactures widgets in the United States through a U$.$S$.$ limited liability company that is treated as a domestic disregarded entity for U$.$S$.$ tax purposes $-$ i$.$e$.,$ a U$.$S$.$ branch of Rio. During the current tax year, the U$.$S$.$ branch of Rio had effectively connected earnings & profits $("$E&P$")$ of $$3,000,000,$ and its U$.$S$.$ net equity was $$1,200,000$ at the beginning of the year and $$1,700,000$ at the end of the year.

$($a$.)$ For U$.$S$.$ tax purposes, compute the U$.$S$.$ branch's dividend equivalent amount and branch profit tax for the current tax year. Assume that the United States does not have a bilateral income tax treaty with Country Y$.(2$ points$)$

Rio's total worldwide liabilities, including U$.$S$.$ booked liabilities, were $$9,000,000,$ while Rio's U$.$S$.$ booked liabilities were $$3,000,000.$ The U$.$S branch paid interest expense of $$90,000$ to a bank in Country $Y.$

During the year, the value of Rio's U$.$S$.$ assets producing effectively connected income were $$4,000,000,$ while the value of Rio's worldwide assets, including U$.$S$.$ assets, were $$24,000,000.$

$($b$.)$ For U$.$S$.$ tax purposes, what is the maximum interest expense deduction that may be taken by the U$.$S$.$ branch for the current tax year? $(3$ points$)$

$($c$.)$ Does the payment or deduction of interest expense by the U$.$S$.$ branch trigger a U$.$S$.$ tax liability $($i$.$e$.,$ a branch tax$)?$ If so$,$ please ideptify the type$($s$)$ of tax and calculate the amount of tax triggered. Again, assume that the United States does not have a bilateral income tax treaty with Country Y$.(1$ point$)$