A CFC may conduct business through a qualified business unit (as defined in §1.989(a)-1) (QBU) that is not treated as a separate entity for federal income tax purposes, either because it is a branch or division of the CFC or because it is a business entity that is disregarded as separate from its owner.
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VPLAN - (no access) - 2017-27320 988 regs.pdf, p8
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