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
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.
Outline
- Introductory comments
- Basic IC-DISC structures
- IC-DISC pricing concepts and examples
- Marginal costing and special no-loss rules
- IC-DISC case study
- Foreign derived intangible income
- IC-DISC and FDII side-by-side
- Complex structures
- "Brother-sister" vs. parent-subsidiary
- Trusts and/or blocker corporations as intermediary structures
- Deferral opportunities
- 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
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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