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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
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IC-DISC marginal costing is generally unavailable when the related purchaser is a CFC, and the sale gives rise to Subpart F foreign base company sales income
/in News/by Paul FerreiraA related supplier generally may not use the IC-DISC marginal costing method for sales of export property where the purchaser is related within IRC §954(d)(3) and the purchaser’s resale gives rise to foreign base company sales income under IRC §954(d). Treasury Regulation §1.994-2(a) states that the marginal costing rules do not apply in that circumstance, […]
When Is Property Sold Through a Distributor “Substantially Transformed” for IC-DISC Purposes?
/in News/by Paul FerreiraFor IC-DISC purposes, a sale through a distributor is not itself the legal test. The real question is whether the property qualifies as export property under IRC § 993(c)(1). That means the property must be manufactured, produced, grown, or extracted in the United States by a person other than the IC-DISC, held primarily for sale […]
Which Industries Can Benefit from an IC-DISC? 2026 Sector Analysis
/in News/by Paul FerreiraIn the current global trade landscape, the question of which industries can benefit from an IC-DISC has moved beyond simple manufacturing. As supply chains reshore and U.S. companies become more vertically integrated, the IC-DISC remains a vital tool for any domestic entity adding significant value to products destined for international markets. Whether your firm is […]