Am I a qualified business unit (QBU)?

I am registered as a self-employed sole proprietor (freelancer) in Japan. Am I considered a qualified business unit (QBU) for US tax purposes? A QBU is defined in Section 989 as: “any separate and clearly identified unit of a trade or business of a taxpayer which maintains separate books and records.” Also defined [here](https://www.irs.gov/pub/int_practice_units/fcu_cu_c_18_3_1_02.pdf), where I am extra confused by this statement: “An individual is not a QBU but may have a QBU with a non-US dollar functional currency.”

The “maintains separate books and records” part of this definition is confusing to me. What constitutes “separate books and records”? All of my business income flows into a personal bank account in my name, and all business/personal expenses are paid through the same account. I do keep track of invoices sent out, and make sure payments are received in a simple spreadsheet. So are my “books and records” separate or combined? Is a self-employed sole proprietor a QBU?

by btbin

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