IC-DISC 2.0: Moving Beyond the Basics to Pricing Commissions and Structuring Complex Corporate Entities
Designing Commission Strategies, Utilizing Trusts, and Setting Up Distributor Companies
Recording of a 90-minute CLE/CPE webinar with Q&A
Conducted on Thursday, February 2, 2017
Recorded event now available
This CLE/CPE webinar will provide tax counsel and advisers with an advanced guide to structuring Interest Charge-Domestic International Sales Corporation (IC-DISC) companies. The panel will go beyond the basics to address alternative and sophisticated structures (including agricultural co-ops), commission grouping strategies, and utilization of IC-DISCs in estate planning contexts. The event will detail state and local impact of various IC-DISC structures and offer illustrations of various specific structuring examples.
The IC-DISC remains the most significant U.S. income tax break for export business owners. The majority of IC-DISC companies are pass-through entities, either S corporations or LLCs. However, the benefits of the IC-DISC structure continue to be under-utilized. In addition to meeting IRS tests for determining qualified export receipts, qualified export assets, and commissions, corporations also must understand and apply all available pricing methods and grouping options in order to achieve the maximum allowable tax benefits.
An IC-DISC structure provides significant tax saving opportunities for more complex entities if the operating documents are structured correctly.
Tax counsel and advisers need to fully grasp the formation rules to ensure that complex IC-DISC ownership structures and operating documents conform to IRS requirements to avail exporters of critical IC-DISC benefits.
Listen as our expert panel provides an advanced and practical guide to structuring IC-DISC companies, going beyond the basics to offer concrete tools to tackle more advanced issues and the challenges of structuring complex IC-DISC entities. The panel will discuss structures for C corporations, using trusts and blocker corporations as intermediaries, commission determination and grouping strategies, and specific drafting techniques.
- Introductory Comments
- Basic IC-DISC structures
- IC-DISC Pricing Concepts and Examples
- Transaction-by Transaction and Grouping Rules
- Marginal Costing and the Overall Profit Percentage Limitation
- Regular and Special No-loss Rules
- IC-DISC Pricing Optimization Case Study
- Complex Structures
- “Brother-sister” vs. parent-subsidiary
- Trusts and/or blocker corporations as intermediary structures
- Deferral opportunities
- Case Study
The panel will discuss these and other important topics pertaining to IC-DISC structuring:
- Understanding IC-DISC Pricing Optimization Mechanics and Documentation
- Determining optimal IC-DISC structures for C corporations, whether closely held companies or corporations with many unrelated shareholders
- Utilizing trusts and blockers for C corporation structures
- Specific drafting tools for various IC-DISC structures beyond basic pass-through entity ownership of IC-DISC companies
After completing this course, you will be able to:
- Distinguish features of more complex IC-DISC structures from basic pass-through entity IC-DISCs
- Decide on strategies for structuring “brother-sister” C corporations in circumstances where parent-subsidiary structures are not appropriate
- Discern when a trust structure would benefit owners of a C Corporation in designing an IC-DISC
- Recognize additional business opportunities under the qualified export receipts definition
- Identify best practices for structuring commission agreements
Mark C. Gasbarra, CPA, National Managing Director
Forte International Tax,
Mr. Gasbarra has more than thirty-five years of international tax experience serving a wide array of companies across many industries. He serves major multinational corporations and CPA firms throughout the U.S., as well as privately held businesses with international operations. He advises on a wide range of international tax matters with deep expertise in outbound issues including repatriation, foreign tax credit utilization, export incentives, including the IC-DISC, and the domestic production activities deduction. Prior to founding Forte in 2004, he was the lead partner in EY's Chicago-based International Tax Services department, and prior to that position, he was an International Tax Service Partner at PwC.
Robert J. Misey, Jr., Shareholder
Reinhart Boerner Van Deuren,
Chicago & Milwaukee
Mr. Misey is attached to the firm's Tax and Business Law Practices, and chairs its International Practice. He works primarily on international taxation and tax controversies for clients in industries ranging from manufacturing to entertainment. He previously spent nine years with the IRS.
Enrolled Agent credit processing is available for an additional fee per person.
EA Processing $5.00
CLE On-Demand - Streaming Video
Note: Self-study CPE and EA credits are not offered on this On-Demand webinar.
Includes recorded streaming video of full program plus PDF handouts.
On-demand is the only recorded format recognized for CLE credits in DE, IN, KS, LA, MS, NC, OH, OK, SC, TN, VA, WI.
AK, AZ, CA, CO, CT, DE, FL, GA, HI, IA, ID, IL, IN*, KS, KY, LA, ME, MN, MO, MT, NC, ND, NH**, NJ, NM, NV, NY, OH*, OK, OR, PA, SC, TN, TX, UT, VA, VT, WA, WI, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)
*Only available for attorneys admitted for more than two years. For OH CLE credits, only programs recorded within the current calendar year are eligible - contact the CLE department for verification.
**NH attendees must self-determine if a program is eligible for credit and self-report their attendance.
CLE On-Demand Video $297.00
Includes full event recording plus handouts.
Note: Self-study CPE and EA credits are not offered on recorded events.
Strafford is an approved provider and self-study CLE credit is available in most states.
AK, AZ, CA, CO, CT, FL, GA, HI, IA, ID, IL, KY, ME, MN, MO, MT, ND, NJ, NM, NY, OR, PA, TN, TX, UT, VT, WA, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)
Strafford will process CLE credit for one person on each recording.
Additional copies of a recording can be purchased at a discount. Please call Strafford Customer Service toll-free at 1-800-926-7926 ext 10 or email firstname.lastname@example.org to place your order.
Recorded Webinar Download $297.00
Recorded Audio Download (MP3) $297.00
DVD (Slide Presentation with Audio) $297.00 plus $9.45 S&H
NASBA CPE Sponsor
Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.
IRS Approved Provider
Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
CLE Credits By State
Strafford is a NASBA CPE sponsor and our live webinars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.
Very clearly presented and very practical advice.
Winthrop Rutherfurd, Jr.
White & Case
I liked that the speakers' explanations of the materials were easy to follow.
Greenebaum, Doll & McDonald
The seminar was given in a very user friendly presentation format.
Strafford webinars are convenient and offer timely topics with knowledgeable presenters.
The presenters were knowledgeable and able to intelligently answer questions.
Mikunda, Cottrell & Co.
Tax Law Advisory Board
Steptoe & Johnson
Morrison & Foerster
Partner and Practice Group Leader - Tax
Waller Lansden Dortch & Davis
Holland & Knight
Partner, Cross-Border Transactions Tax
Fraser Milner Casgrain
Federal Tax Partner
Partner, Tax-Exempt Organizations
Steptoe & Johnson
Partner, Corporate Tax and Due Diligence
Ivins, Phillips & Barker
Managing Director, State and Local Tax Practice
Partner & Co-Chair, State & Local Tax Practice
Sutherland Asbill & Brennan
Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.