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
A 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, […]


