IC-DISC Strategies: Mastering the Complex Operational Challenges
Anticipating IRS Audit Risks, Calculating Commissions, and Tackling Computational Intricacies
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will prepare accounting professionals and tax advisers to fully leverage the tax benefits of IC-DISC formation. The panel will review and explain the key strategic steps for day-to-day aspects of running an IC-DISC, including calculating commissions, spotting IRS audit risks, and tackling the complex computations required. The panel will also outline key IC-DISC tax planning opportunities, including using the best DISC ownership structures to maximize DISC benefits.
Outline
- IC-DISC overview
- Applicable IRC sections
- Tax court decisions and IRS guidance
- Implementing an IC-DISC
- IC-DISCs future
- Updated IC-DISC ownership structures
- Structuring and implementing IC-DISCs
- Day-to-day operating issues
- IRA ownership of IC-DISCs
- Saving Disqualified IC-DISCs
- Compliance and reporting
- Pricing rules
- Computational challenges
- Calculating commissions
- Transaction-by-transaction computations
- Reg 1.861-8 computations
- Other issues
- Considerations after the 2017 Tax Act
- Tax filings and common compliance pitfalls
Benefits
The panel will guide you through issues including:
- Maximizing unique IC-DISC tax benefits such as the tax benefits from different shareholder structures
- Understanding tax liability for DISC structures and the QBID
- Managing day-to-day operational aspects of using an IC-DISC
- Improving liquidity for the parent and shareholders: steps to consider
- Overcoming computational challenges
Faculty
Ben Cote, CPA
Senior Manager
Plante & Moran
As a senior manager in the international tax services area at Plante Moran, Mr. Cote serves clients in a wide range of... | Read More
As a senior manager in the international tax services area at Plante Moran, Mr. Cote serves clients in a wide range of industries and has broad expertise in international taxation, including cross-border entity structuring, tax compliance in both inbound and outbound structures, tax treaty analysis, and foreign tax credits. He is a specialist in US export incentives including the IC-DISC and FDII regimes.
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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
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.
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Robert J. (Rob) Misey, Jr.
Shareholder
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
Mr. Misey, Jr. is chair of the firm’s International Practice. He serves with a wide range of clients involved in an array of industries such as manufacturing, distribution, sport and entertainment with international taxation and tax controversy matters. Licensed in California, Wisconsin, Kentucky and Washington, D.C., he is also a member of the International Fiscal Association, chair of the Tax Committee of International Section of the American Bar Association, and a member of Wisconsin Accounting Examining Board. He previously spent nine years with the IRS.
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