(a) A qualified taxpayer and its affiliates shall be presumed to be a part of a unitary business and all income of that business shall be presumed to be apportionable business income if a valid water's-edge election has been made, except as provided in subsections (c) and (d) of section 63-3027C , Idaho Code. (b) A taxpayer shall have the burden of proof regarding the issue of whether or not a corporation is a member of a water's-edge combined group.
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