IC-DISC Tax Law Challenges: Structuring and Planning Techniques to Maximize Tax Savings Post-Tax Reform

Navigating Applicable IRC Sections, Formation and Qualification Issues, and Capturing Maximum Tax Benefits

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

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Conducted on Wednesday, May 22, 2019

Recorded event now available

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Course Materials

This CLE/CPE course will provide tax counsel and advisers with the guidance necessary to maximize the powerful tax benefits of the interest charge domestic international sales corporation (IC-DISC). The panel will review the complex requirements of applicable IRC sections, formation best practices, qualification issues and the implications of tax reform.

Description

U.S. tax law under the 2017 tax reform retained the export tax benefit under the IC-DISC structure for companies that export products. If formed properly, taxpayers can benefit from federal income tax savings.

The repeal of the domestic production activity deduction and the addition of the new limitation of interest deduction within the new tax law require tax counsel and advisers to consider all relevant tax reform changes to determine the overall impact to a company's IC-DISC benefits. After that, tax saving opportunities can be leveraged by export business clients by perfecting the knowledge of the IRC sections, the implications of tax reform, and reconciling the difference in the application of the benefits of an IC-DISC structure to S corporations or partnerships versus C corporations.

Listen as our experienced panel reviews structuring techniques to maximize the federal tax savings for domestic corporations that primarily engage in foreign sales and exporting activity. The panelists will focus on the IRC sections, formation, implications of tax reform, benefits and qualification issues.

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Outline

  1. Applicable IRC sections
  2. Formation
    1. Drafting the contract between IC-DISC and manufacturing company
    2. Appropriate legal entity
    3. Implementation
  3. Partnerships/S corporations versus C corporations
  4. Qualification issues
    1. Qualified export receipts
    2. Qualified export assets
    3. Dividends
  5. Best practices for capturing the maximum tax benefit

Benefits

The panel will review these and other critical issues:

  • What benefits does the IC-DISC structure provide to export companies?
  • What are the implications of the new tax law?
  • What are the best practices for forming the IC-DISC structure to maximize tax benefits?
  • What are the considerations when utilizing the IC-DISC structure as it applies to S corporations and partnerships versus C corporations?
  • What are the qualification issues?

Faculty

Ghassemieh, Mehrdad
Mehrdad Ghassemieh

Partner
Harlowe & Falk

Mr. Ghassemieh's practice focuses on assisting companies of all sizes, in all business and tax matters,...  |  Read More

Lucas, Dante
Dante Lucas
Managing Director - International Tax
KPMG

Mr. Lucas is an advisor to U.S. and foreign multinational, middle-market and closely-held corporations in a wide range...  |  Read More

Misey, Robert
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

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