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CALIFORNIA FRANCHISE TAX BOARD Rev.: January 2004 Internal Procedures Manual Page 1 of 18 Water's Edge Manual Table of Contents CH. 1 1.1 a. b. INTRODUCTION.

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“The water's edge election provides assurance that the affiliates of foreign-based companies filing on a water's edge basis in California will not be taxed on the same income both in a foreign country in which they are doing business and in California.

H. Where to File Mail Form 100W with payment to: Mail Franchise Tax Board. PO Box 942857. Sacramento CA 94257-0501. e-filed returns: Mail form FTB 3586, Payment Voucher for Corporations and Exempt Organizations e-filed Returns, with payment to: Mail Franchise Tax Board. PO Box 942857. Sacramento CA 94257-0531.

In a water's-edge filing, transactions between domestic and foreign entities (that are presumably not included in the combined group) are not eliminated. However, under a worldwide combined election, the transactions may be eliminated as transactions between members of the combined group.

Water's-edge tax returns must reflect combined reports of corporations engaged in a unitary business. Depending on the tax year, they employ a three-factor apportionment formula (reflecting a property factor, a payroll factor and a sales factor) or single sales factor apportionment formula.

The election is made via Form 100-WE and must be attached to a timely filed original return Form 100W. The election lasts for 84 months (7 years).

A water's-edge election must be for an initial term of 84 consecutive months (R&TC §25113(c)(9)), and it remains in effect thereafter, year after year, until the taxpayer chooses to timely terminate it. (R&TC §25113(c)(12).)

The water's edge election eases international tensions on trade by allowing California to tax income earned within the United States. Foreign governments do not believe that California should infringe upon trade agreements between the United States and foreign governments. Protects Against Double Taxation.

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© Copyright 1997-2025
airSlate Legal Forms, Inc.
3720 Flowood Dr, Flowood, Mississippi 39232
Form Packages
Adoption
Bankruptcy
Contractors
Divorce
Home Sales
Employment
Identity Theft
Incorporation
Landlord Tenant
Living Trust
Name Change
Personal Planning
Small Business
Wills & Estates
Packages A-Z
Form Categories
Affidavits
Bankruptcy
Bill of Sale
Corporate - LLC
Divorce
Employment
Identity Theft
Internet Technology
Landlord Tenant
Living Wills
Name Change
Power of Attorney
Real Estate
Small Estates
Wills
All Forms
Forms A-Z
Form Library
Customer Service
Terms of Service
DMCA Policy
About Us
Blog
Affiliates
Contact Us
Privacy Notice
Delete My Account
Site Map
Industries
Forms in Spanish
Localized Forms
State-specific Forms
Forms Kit
Legal Guides
Real Estate Handbook
All Guides
Prepared for You
Notarize
Incorporation services
Our Customers
For Consumers
For Small Business
For Attorneys
Our Sites
US Legal Forms
USLegal
FormsPass
pdfFiller
signNow
airSlate workflows
DocHub
Instapage
Social Media
Call us now toll free:
1-877-389-0141
As seen in:
  • USA Today logo picture
  • CBC News logo picture
  • LA Times logo picture
  • The Washington Post logo picture
  • AP logo picture
  • Forbes logo picture
© Copyright 1997-2025
airSlate Legal Forms, Inc.
3720 Flowood Dr, Flowood, Mississippi 39232