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All Eyes on the I.C.-D.I.S.C. Part Two: I.R.S. Examinations

All Eyes on the I.C.-D.I.S.C. Part Two: I.R.S. Examinations

The Interest Charge Domestic International Sales Corporation (“I.C.-D.I.S.C.”) is an undervalued tax planning tool for exporters that can provide substantial tax advantages to U.S. export companies and their shareholders. In the March edition of Insights, Michael Bennet addressed the technical aspects, and tax benefits of the I.C.-D.I.S.C. In this month’s edition, he addresses Part Two reviewing the I.R.S. examination procedure and key aspects taxpayers should keep in mind. Based on the I.C.-D.I.S.C. audit guide published by the I.R.S., the article explains the steps that should be followed to stand up to the questions that will be asked by the examiner. Those who read Part One are strongly urged to read Part Two to understand the internal steps to be taken to ensure the I.C.-D.I.S.C. benefit is real after an I.R.S. examination is completed.

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All Eyes on the I.C.-D.I.S.C. Part I: the Export Gift That Keeps on Giving.

All Eyes on the I.C.-D.I.S.C. Part I: the Export Gift That Keeps on Giving.

Regardless of their political affiliations, presidential administrations and members of Congress share the goal of maintaining U.S. competitiveness on the global market. We often hear statements directed toward strengthening the U.S. manufacturing sector and bringing production activity back to the U.S. These words would be futile without implementing initiatives favoring U.S. business interests. An often-overlooked incentive is the Interest Charge Domestic International Sales Corporation (“I.C.-D.I.S.C.”) regime. For an export business operated in the form of an L.L.C. owned by individuals, an I.C.-D.I.S.C. can produce tax savings for export profits of about 40% for the owners, when operated properly. More importantly, it can be run on automatic pilot once set up. In Part I of a two-part series, Michael Bennett explains the basics of setting up and operating an I.C.-D.I.S.C. In Part II, he will discuss issues that have been raised in years past when the goal of a D.I.S.C. was to promote exports by permanently deferring the export profits rather than recognize taxable income immediately, but at lower rates.

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