Читать книгу International Taxation - Adnan Islam - Страница 55

Assume, in example 2-6, that Sessions creates a Japanese subsidiary to carry on the courier activities. The subsidiary is a QBU because a corporation, whether or not it has a trade or business, is a QBU.

An individual is not a QBU, but an individual may have a QBU including a trade or business for which separate records are kept. Section 989(a).