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) Potential exemption of US tax on income earned by the corporation

B) Flow-through of losses from the German corporation to the tax return of the US corporation

C) Limited liability to the US corporation for acts committed by the hybrid entity

D) Free transferbility of the stock of the hybrid entity by the US corporation

Please explain