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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
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IC-DISC No Loss Rule – What Exporters Must Know
/in News/by Paul FerreiraOne overlooked rule can wipe out your IC-DISC tax savings. For U.S. exporters using the Interest Charge Domestic International Sales Corporation (IC-DISC) structure, the opportunity for federal tax savings is significant. But so are the compliance risks. The IC-DISC No Loss Rule is one such risk, and it’s often misunderstood or entirely overlooked until it’s […]
Export Promotion Expenses and the IC-DISC – Statutory, Regulatory, and Judicial Analysis for Commission DISCs
/in News/by Paul FerreiraThe Interest Charge Domestic International Sales Corporation (IC-DISC) regime remains a powerful tool for U.S. exporters, offering significant tax benefits by allowing a portion of export income to be taxed at favorable rates. A critical component of the IC-DISC calculation is the treatment of “export promotion expenses,” which can increase the amount of income allocated […]
PLRs and Interest of Government not Prejudiced
/in News/by Paul FerreiraNot Prejudicing the Interests of the Government under Treas. Reg. § 301.9100-3 Regarding a late-filed IC-DISC Election (Form 4876-A) In the context of Treas. Reg. § 301.9100-3, when the IRS considers granting an extension of time to make a regulatory election (such as filing Form 4876-A to elect IC-DISC status), a key requirement is that […]