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 premium CLE/CPE webinar with Q&A

Conducted on Tuesday, September 24, 2019

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 the state and local impact of various IC-DISC structures and offer illustrations of various specific structuring examples along with post-tax reform considerations.


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 to achieve the maximum allowable tax benefits.

Tax professionals must recognize available structures for C corporations, the advantages (for some entities) of IC-DISC, using trusts and blocker corporations as intermediaries, commission determination and grouping strategies, and specific drafting techniques. Also, advisers must carefully consider 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.



  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


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


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. (Rob) Misey, Jr.

Reinhart Boerner Van Deuren

Mr. Misey, Jr. is chair of the firm’s International Practice. He serves with a wide range of clients involved in...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include program handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video