Entries by Paul Ferreira

Are IC-DISC Dividends Qualified? A Complete Guide

Navigating 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 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

Taxpayers 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 […]

Update on the IC-DISC – Schedule K-2/K-3 and the IC-DISC Dividend

The IRS’s expanded international reporting requirements have made it essential for S corporations and partnerships with IC-DISCs to understand how to properly report dividends on Form Schedule K-2/K-3. Below is a summary of key developments that may affect Forms 1120S or 1065. Table of Contents: 1. Schedule K-2/K-3 Applies to Pass-Through Entities with International Activity […]

Form 8404 – Essential Filing Guide for Exporters (2025)

For exporters using the Interest Charge Domestic International Sales Corporation (IC-DISC) structure, staying compliant with IRS regulations is essential to maintaining tax benefits.  One key requirement is IRS Form 8404, Interest Charge on DISC-Related Deferred Tax Liability, which calculates the interest charge on deferred taxes tied to IC-DISC profits. Why is Form 8404 Important? With […]

IC-DISC Benefits – 6 Key Tax Advantages for Exporters

IC-DISC benefits are one of the primary reasons businesses file for this corporate structure change. As a company branches into international sales, the tax incentive can hold over money that can be spent on warehousing, product development, and more. What are the benefits of IC-DISC? IC-DISC tax benefits include tax deferrals, estate-planning aids, reduced federal […]

International Tax Planning – Key Strategies for Export Success

In 2024, international tax planning remains a critical factor for businesses engaged in cross-border trade. Navigating this complex landscape requires strategies to reduce tax liabilities, optimize compliance, and leverage available export incentives.International tax planning involves creating tax-efficient structures for businesses operating globally to minimize liabilities and maximize compliance across jurisdictions. Effective planning is essential for […]

IC-DISC Interest Charge – Maximizing Tax Savings for Exporters

The Interest Charge Domestic International Sales Corporation (IC-DISC) provides a valuable tax incentive for U.S. businesses engaged in exporting. Companies can enjoy significant tax savings by deferring taxes on export-related profits. However, to fully benefit from this structure, businesses need to understand and manage the IC-DISC interest charge—a requirement that ensures taxes deferred under the IC-DISC are not held indefinitely […]

IC-DISC Accounting – Tax Strategies Every Exporter Should Know

In July 2025, U.S. exports of goods and services reached a record high of $265.9 billion, according to the U.S. Census Bureau. This growth offers U.S. exporters a tremendous opportunity, and one way to capitalize on it is through the IC-DISC structure, which helps businesses boost profitability by cutting down on taxes. So, how does […]

IC-DISC Distributions 2025 – Essential Tips from Experts

Imagine significantly reducing your tax burden on export sales. For many U.S. businesses venturing into the global marketplace, this dream becomes a reality thanks to a powerful tool: the Interest Charge Domestic International Sales Corporation (IC-DISC). But unlocking the full potential of IC-DISCs hinges on understanding their distribution strategies. IC-DISC distributions are crucial for export […]