In the broadest application of the unitary theory, the U.S. unitary business files a combined tax return using factors and income amounts for all affiliates:

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The unitary theory, in its broadest application, allows for the filing of a combined tax return that includes factors and income amounts for all affiliates of a U.S. unitary business, regardless of where those affiliates are organized. This means that it encompasses affiliates organized anywhere in the world, not limited to the United States, NAFTA countries, or countries with specific tax treaties with the United States.

In the Broadest Application of the Unitary Theory, the U