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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
Architects, the IC-DISC and Marginal Costing
/in News/by Paul FerreiraArchitectural and engineering firms can qualify for IC-DISC benefits, but only for a narrow category of foreign-project services. The governing rule is that gross receipts for engineering or architectural services are qualified export receipts only if the services relate to construction projects located, or proposed for location, outside the United States. Those receipts can help […]
The IC-DISC and Transfer Pricing
/in News/by Paul FerreiraIC-DISC benefits can apply to export sales involving related foreign distribution structures, including a foreign disregarded entity or branch and a controlled foreign affiliate, but the IC-DISC rules and section 482 transfer pricing rules are separate regimes and both must be satisfied. A sale may qualify as a DISC sale even when the immediate customer […]
Defining the IC-DISC year-end – why shareholder conformity matters
/in News/by Paul FerreiraAn IC-DISC is not free to choose any convenient year-end. Although taxpayers generally compute taxable income based on their taxable year under IRC section 441(a), Congress imposed a special rule for DISCs. Under section 441(h)(1), the taxable year of a DISC is the taxable year of the shareholder, or group of shareholders with the same […]