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Contact Us
Set up a consultation to explore how our expertise can offer insights and strategies, enhancing your federal income tax savings in ways you haven’t seen before.
Call Us: 857.453.1005
Are IC-DISC Dividends Qualified? A Complete Guide
/in News/by Paul FerreiraNavigating the U.S. tax code can be a challenge—especially for export-driven businesses aiming to reduce their tax burden without running afoul of regulations. One little-known but highly effective strategy is the use of an Interest Charge Domestic International Sales Corporation, or IC-DISC. IC-DISC dividends can be considered qualified dividends if they meet specific IRS requirements. […]
AM 2022-005 – Treaty Override Rejected for DISC Distributions to Foreign Shareholders
/in Uncategorized/by Paul FerreiraIn IRS Advice Memorandum AM 2022-005, the Office of Chief Counsel reaffirmed that distributions from a Domestic International Sales Corporation (DISC) to foreign shareholders are treated as effectively connected income (ECI) under Internal Revenue Code § 996(g), even where an applicable U.S. income tax treaty would otherwise provide reduced withholding rates on dividends. This position […]
Quick Update: IC-DISC Dividends and Schedule K-2/K-3
/in News/by Paul FerreiraTaxpayers utilizing an IC-DIS should note the continuing importance of Schedules K-2 and K-3 in reporting international income. Since 2022, S corporations and partnerships receiving IC-DISC dividends must include this information to comply with the requirements of Schedule K-2/K-3. Although IC-DISCs are domestic entities (Treas. Reg. § 1.992-1(a)(1)), dividends paid by an IC-DISC are classified […]