21 - What entities are included in a water's edge report?
This reporting requirement no longer exists for tax years beginning after December 31, 2010
All members of a corporate group that are in a unitary business and are:
- i. Organized or incorporated in the United States, including those corporations qualifying for Puerto Rico and Possession Tax Credit as provided in IRC Section 936, or
- ii. Corporations organized or incorporated outside of the United States whose business activity in the United States is 20% or more of the corporation's total business activity. Foreign corporations that conduct 20% or more of their business activity in the United States, as measured by the average of the property and payroll factors, must be included 100% in a water's edge combined report.