English to Polish Law/Patents Law (general) general

Montana requires a worldwide combined return for unitary groups of affiliated corporations unless an election to file on “water’s edge” basis has been made. A “water’s edge” election typically only includes income that is generated in the US. In order to file on “water’s edge” basis in Montana, a Montana Water’s Edge Election (Form WE-ELECT) must be filed with the Montana Department of Revenue, which is (in essence) an application requesting approval by the Montana Department of Revenue to file on “water’s edge” basis. If the Montana Department of Revenue grants approval, it is binding on the taxpayer/filer for three years. Based on our reading of the Target’s Montana corporate income returns provided for our review, the Target did not indicate that it filed on a water’s edge basis and the Water’s Edge Schedule (WE-Schedule) was not included with the returns filed, as required (the Water’s Edge Schedule, in essence, removes income from foreign operations of US entities so that the final income reflected will be only US income).