IC-DISC and FDII: U.S. Export Incentives Post-Tax Reform, Pricing Commissions and Structuring Corporate Entities

Maximizing Tax Savings, Pass-Through Entities vs. C-Corporations, Distributor Companies and Alternative Ownership Structures

Recording of a 90-minute CLE/CPE webinar with Q&A


Conducted on Tuesday, July 31, 2018

Recorded event now available

or call 1-800-926-7926
Program Materials

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 along with post-tax reform considerations.

Description

The IC-DISC survived tax reform and can still be a significant U.S. income tax break for some export business owners. 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.

Tax professionals must recognize available structures for C corporations whom may find advantages of IC-DISC, using trusts and blocker corporations as intermediaries, commission determination and grouping strategies, and specific drafting techniques. In addition, careful consideration must be given to the newly enacted Foreign-Derived Intangible Income Deduction (“FDII”) available for C-Corporations.

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 post-tax reform.

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Outline

  1. Introductory comments
  2. Basic IC-DISC structures
  3. IC-DISC pricing concepts and examples
  4. Marginal costing and special no-loss rules
  5. IC-DISC case study
  6. Foreign-derived intangible income
  7. IC-DISC and FDII side-by-side
  8. Complex structures
    1. “Brother-sister” vs. parent-subsidiary
    2. Trusts and/or blocker corporations as intermediary structures
    3. Deferral opportunities
  9. Case studies

Benefits

The panel will review these and other essential topics about 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
  • The impact of tax reform and circumstances where tax benefits are available
  • Specific drafting tools for various IC-DISC structures beyond basic pass-through entity ownership of IC-DISC companies

Faculty

Gasbarra, Mark
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...  |  Read More

Misey, Robert
Robert J. Misey, Jr.

Shareholder
Reinhart Boerner Van Deuren

Mr. Misey is attached to the firm's Tax and Business Law Practices, and chairs its International Practice. He...  |  Read More

Other Formats
— Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video

$297

Download

CPE Not Available

$297