For purposes of this paragraph, the term contract manufacturing or production arrangement means any arrangement under which— (i) a person contracts with one or more unrelated persons for the manufacture, production, growth or extraction of an item of qualifying production property or a qualified film, and (ii) in the case of qualifying production property, such item of qualifying production property is manufactured, produced, grown or extracted in whole or significant part within the United States pursuant to subsection (c)(4)(A)(i)(I). (D) Factors for determining substantial contribution The Secretary shall prescribe regulations setting forth activities to be taken into account in determining whether a person makes a substantial contribution through the activities of its employees within the United States to the manufacture, production, growth or extraction of qualifying production property for purposes of subparagraph (A). Such factors shall include— (i) oversight and direction of the activities or process pursuant to which the property is manufactured, produced, grown or extracted