21. What entities are included in a water's edge report?

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.