ABC Corporation conducts a retail merchandise business in the United States. It has a subsidiary in England, ABC Ltd., and in Germany, ABC GmbH. These foreign subsidiaries do their own buying and manage their day-to-day operations independent of the parent, ABC Corporation. They sell only in the markets in the countries in which they are located. ABC Corporation performs certain services for the subsidiaries at cost; including accounting, advertising, legal, insurance and employee benefits. Are these corporations engaged in a unitary business so that ABC Corporation is required to file a combined report in California and New York? Would your analysis be different if the questions was asked in 2014 versus 2020?