"[R]egistrants can use reasonable beliefs, estimates, assumptions, methodologies and statistical sampling in determining median employee compensation, including: [1] Using existing internal records that are reasonably reflective of annual compensation ... to determine median compensation ... as well as to determine if its non-US population is de minimis ... and thus excludable. [2] Ascertaining whether an individual is an independent contractor according to another 'widely recognized test' (e.g., the 20-factor test commonly used by the IRS)[.]"  MORE >>