Читать книгу International Taxation - Adnan Islam - Страница 45

In a manner similar to the net profit method, foreign branches that are QBUs must compute their net income as if the branch had a closed balance sheet like that of a separate corporation. Also, certain QBUs must keep their books on the basis of the U.S. dollar. However, some QBUs, meeting certain qualifications, may keep their books on the basis of a foreign currency and must follow specific rules for computing taxable income on that basis.

Only a QBU is entitled to elect to keep its books in terms of a foreign currency. A QBU is a business operation that is a “separate and clearly identified” unit of a company. The regulations provide that a QBU must be a complete business including every operation that ordinarily forms a part of that particular business. A QBU may not perform one or more functions that merely are a part of another business. A corporation may have more than one QBU.