In determining a corporation's payroll, property and sales factors in the United States under AS 43.20.145(a)(1) and (4), the following rules apply:

1. (1) the rules for inclusion, value, and attribution of apportionment factors for the water's edge combined group must be determined under AS 43.19 and the regulations adopted under that chapter;
2. (2) when computing the apportionment factors of the water's edge combined group, an intercompany transaction between members of the group must be eliminated;
3. (3) a transaction between a member of the water's edge combined group and a corporation not included in the group must be included when determining apportionment factors; and
4. (4) the average of the factors is calculated under AS 43.19.010, Article IV, except that each factor is determined by placing in the numerator the elements of the factor in the United States and by placing in the denominator the elements of the factor worldwide; if a corporation has no sales, property, or payroll, the average is determined by eliminating that factor or factors from the computation, and dividing by the remaining number of factors.

(Eff. 7/9/93, Register 127)

Authority: AS 43.05.080