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This is what closing the "water's edge" loophole would force corporations to do.
What is include their U.S. profits held in offshore tax havens when calculating taxes.
In many states, companies calculate their taxes based on their income held in subsidiaries incorporated within the water’s edge (that is, within the United States). By declaring a list of tax havens in the law, states can tax corporate profits held in tax havens that lie past the "water’s edge."