Which of the Following Tax or Non-Tax Benefits Does Not

Which of the following tax or non-tax benefits does not arise when a U.S. corporation forms a hybrid entity in Germany through which to earn business profits in Germany and elects to have the entity treated as a branch for U.S. tax purposes?

A) Flow-through of losses from the German corporation to the tax return of the U.S. corporation.
B) Free transferability of the stock of the hybrid entity by the U.S. corporation.
C) Potential deferral of U.S. tax on income earned by the corporation.
D) Limited liability to the U.S. corporation for acts committed by the hybrid entity.