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1 States Conform to Beneficial Federal Tax Treatment of IC ...
https://www.bakerdonelson.com/Spotlight-on-SALT-More-States-Conform-to-Beneficial-Federal-Tax-Treatment-of-IC-DISCs-03-06-2014
An IC-DISC is usually established as a commission-based entity and a portion of the U.S. exporter's export sales gross receipts are treated as a ...
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2 Tax Alert | Implementing an IC-DISC - HCVT, LLP
https://www.hcvt.com/alert-IC-DISC-For-Export-Business
Elects to be treated as an IC-DISC; Maintains of a separate bank account; Keeps annual accounting records; Files annual income tax returns; Has $2,500 in ...
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3 Instructions for Form 1120-IC-DISC (Rev. December 2021) - IRS
https://www.irs.gov/pub/irs-pdf/i1120icd.pdf
A commission DISC (one that is treated as if it were a commission agent for a principal who sold outside the U.S.). The commission type DISC has ...
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4 IC-DISC | Exporter Tax Incentives - KBKG
https://www.kbkg.com/ic-disc
The Interest Charge Domestic International Sales Corporation (IC-DISC) offers significant Federal income tax savings for making or ...
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5 Reassessing the tax benefits of IC-DISCs
https://www.thetaxadviser.com/issues/2018/oct/reassessing-tax-benefits-ic-discs.html
S corporation shareholder tax benefit rate for commission deduction = 37% × 80% = 29.6%. · S corporation shareholder tax rate on IC-DISC ...
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6 California Treatment of Transactions Between IC DISCs and ...
https://www2.deloitte.com/us/en/pages/tax/articles/multistate-tax-alert-california-treatment-of-transactions-between-ic-discs-and-their-owners.html
For an IC DISC organized under California law or registered with the California Secretary of State, the corporation designated as the IC ...
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7 IC-DISC still offers permanent tax savings for exporters
https://www.bakertilly.com/insights/ic-disc-still-offers-permanent-tax-savings-for-exporters
A domestic C corporation must request and receive IRS approval to be treated as an IC-DISC for federal tax purposes. It also must maintain its own bank account, ...
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8 Interest Charge Domestic International Sales Corporation ...
https://answerconnect.cch.com/topic/ad4f720e7c6a1000a5d490b11c18c902022/interest-charge-domestic-international-sales-corporation-taxation-of-income-to-shareholders
Tax treatment of an IC-DISC distribution is based on whether the distribution is made from previously taxed income, accumulated, tax deferred IC-DISC income ...
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9 IC-DISCs: Tax Savings for Exporters - Morse
https://www.morse.law/news/ic-disc/
In some cases, depending on the tax status of the exporter and state tax treatment of the IC-DISC, the exporter entity may directly own the ...
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10 U.S. exporters leaving tax dollars on the table
https://www.journalofaccountancy.com/issues/2016/nov/interest-charge-domestic-international-sales-corporations.html
States vary on their treatment of IC-DISCs. · Once the IC-DISC is formed, it must continue to meet maintenance requirements to retain its tax- ...
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11 IC-DISCs: Structuring to Maximize Tax Benefits
https://www.reinhartlaw.com/wp-content/uploads/2015/09/IC-DISCs-Structuring-to-Maximize-Tax-Benefits.pdf
The export property must be held primarily for sale, consumption or disposition outside the United States. Sales to a U.S. customer, who subsequently exports.
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12 Legal Ruling - 2015-02 - Franchise Tax Board
https://www.ftb.ca.gov/tax-pros/law/legal-rulings/2015-02.pdf
What is the proper treatment for California tax purposes of transactions between corporations designated as an IC DISC for federal tax ...
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13 IC-DISCs - Export Virginia
https://exportvirginia.org/sites/default/files/2022-03/VEDP_Export%20Guide_IC-DISC.pdf
(IC-DISC) is a tax saving vehicle for U.S. exporters. ... state income tax treatment of IC-DISCs ... (Source: “More States Conform to Beneficial Federal.
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14 Wisconsin Tax Bulletin 197 - April 2017
https://www.revenue.wi.gov/WisconsinTaxBulletin/197-04-17-combined.pdf
IC-100. 1. Table of Contents. Who Must File Form 4 . ... Corporations (IC-DISCs) . ... Section 11146 of P.L. 109-59, the tax treatment of state.
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15 ID-DISC CORPORATIONS COMPLETE &amp - AmeriLawyer
https://www.amerilawyer.com/incorporate/form_a_icdisc
INCLUDES FREE IC-DISC Corporation State Filing Fees and Complete ... The new corporation must formally elect to be treated as an IC-DISC and must also file ...
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16 Oregon Farmers with Export Business should consider IC ...
http://www.friendsoffamilyfarmers.org/wp-content/uploads/2013/12/IC-DISC_Oregon_FINAL_KJD-.pdf
First, the farmer creates a corporation under state law. Then the corporation files an election with the IRS to be treated as an IC-DISC. Upon approval, that ...
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17 IC-DISC Tax Incentive Qualification Basics
https://www.internationaltaxseattle.com/ic-disc-basics-of-the-ic-disc-export-ta
A domestic corporation may elect IC-DISC status by filing IRS Form 4876-A, Election to be Treated as an Interest Charge DISC (see ...
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18 The IC-DISC: How Your Foreign Sales Can Save You Tax
https://www.bpw.com/blog/2014/07/22/the-ic-disc-how-your-foreign-sales-can-save-you-tax/
Because IC-DISCs are exempt from federal taxation, they pay no tax on the commission income. Nevertheless, a tax deduction is allowed for your ...
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19 IC-DISC: What is it, How does it work? - LBMC
https://www.lbmc.com/blog/what-is-ic-disc-how-does-it-work/
An Interest Charge Domestic International Sales Corporation, or IC-DISC, offers a significant federal income tax savings for making or ...
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20 How Sweeping Federal Tax Reform May Create Benefits (and ...
https://www.fiscalexcellence.org/policy/income-taxes/FF-JanFeb2018-TCJA-CorpTax.html
At 9.8%,4 Minnesota has one of the highest state corporate income tax rates in ... of these provisions, similar to how the state treated DPAD and IC-DISC's.
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21 Instructions for Form CT-3 - Tax.NY.gov
https://www.tax.ny.gov/pdf/current_forms/ct/ct3i.pdf
you are a federal QSSS where New York State does not follow federal QSSS treatment; or. • you have affiliated entities. Tax-exempt DISCs – A corporation ...
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22 IC-DISC | Export Tax Incentive | OH | KY | IN - Barnes Dennig
https://www.barnesdennig.com/service/tax-services/international/ic-disc/
state planning flexibility by increasing shareholders' overall liquidity. If you export internationally, an IC-DISC may provide additional tax savings, but it's ...
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23 Frequently Asked Questions - Louisiana Department of Revenue
https://revenue.louisiana.gov/faq/Details/1217
Interest and dividends from all state and local government obligations are exempt from federal income tax. Louisiana only exempts interest and dividends from ...
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24 Extension Granted to File IC-DISC Election - Tax Notes
https://www.taxnotes.com/research/federal/irs-private-rulings/letter-rulings-%26-technical-advice/extension-granted-to-file-ic-disc-election/28jgr
The IRS granted a corporation an extension to file an election to be treated as an interest charge domestic international sales corporation.
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25 Think of the IC-DISC as a tax-saving machine - Ruder Ware
https://www.ruderware.com/wp-content/uploads/2019/10/TBN0413_001AEW_23.pdf
the united states)?” have you ever wondered ... On $10,000 of income, an iC-DisC could ... corporation elects to be treated as an iC-DisC by.
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26 Using an IC-DISC Structure to Reduce Taxes on Foreign Exports
https://gallerosrobinson.com/insight-inside/using-an-ic-disc-structure-to-reduce-taxes-on-foreign-exports/
The IC-DISC is a federal tax export incentive entity structuring available for U. S. ... the following transactions may also qualify for IC-DISC treatment:.
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27 TC-20 Forms & Instructions - Corporation Franchise & Income ...
https://tax.utah.gov/forms/current/tc-20inst.pdf
Utah State Tax Commission • 210 North 1950 West • Salt Lake City, Utah 84134 • tax.utah.gov ... TC-20 if Corporation filed federal form 1120, 1120-IC-DISC.
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28 What's an IC-DISC and why would you want one? - Wipfli
https://www.wipfli.com/insights/blogs/taxthink/160818-icdisc
Be a C corporation organized in the United States, · Have a single class of stock, · File an election to be treated as an IC-DISC, · Maintain a ...
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29 IC-Disc May Be A Good Idea For Your New Jersey Business
https://scarincihollenbeck.com/law-firm-insights/tax/business-tax-law-firm-insights/consider-ic-disc-business
An IC-Disc reflects a special tax preference enacted by Congress to strengthen export sales. If a domestic corporation qualifies and elects to ...
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30 Special tax treatment for exporters - Global Trade Alert
https://www.globaltradealert.org/intervention/12525/export-tax/united-states-of-america-state-of-virginia-special-tax-treatment-for-exporters
... 2014 that will provide special state income tax treatment for exporters that form an Interest Charge-Domestic International Sales Corporation (IC-DISC).
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31 Form OR-20 Instructions Oregon Corporation Excise Tax
https://www.oregon.gov/dor/forms/FormsPubs/form-or-20-instructions_102-020-1_2021.pdf
File corporate tax returns through the Federal/State Electronic Filing Program. ... If your corporation is an IC-DISC, file Form OR-20 and.
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32 IC-DISC | International Tax Planning | Detroit CPA
https://claytonmckervey.com/ic-disc/
The United States has continually offered encouragement and support to domestic companies to promote export sales of domestically produced goods.
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33 Interest-Charge Domestic International Sales Corporations (IC ...
https://www.fosterswift.com/communications-632.html
An IC-DISC is a C-corporation that is exempt from all forms of federal taxation (although some states tax IC-DISCs as C-corporations). Usually, an IC-DISC ...
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34 DEPARTMENT OF TAXATION 2014 Fiscal Impact Statement
https://lis.virginia.gov/cgi-bin/legp604.exe?141+oth+SB515F161+PDF
active IC-DISCs in the United States in Taxable Year 1996. ... DISC income would have been treated as dividends for Virginia purposes and ...
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35 TAX DEVELOPMENT JOURNAL
https://www.csun.edu/sites/default/files/ghassmiehfinal_0.pdf
IC-DISC in retirement and estate planning. I. IC-DISC OVERVIEW. Sections 991 through 997 of the Internal Revenue Code govern the tax treatment of IC-DISCs.
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36 Deferred Income and Tax Liability Treatment - McGuire Sponsel
https://mcguiresponsel.com/blog/deferred-income-and-tax-liability-treatment/
It was at this point the “IC” portion of the “IC-DISC” came into being. As such, IRC § 995(f)(1) states “A shareholder of a DISC shall pay for each taxable ...
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37 How An IC-DISC Can be Used to Defer Tax On Commissions ...
https://sftaxcounsel.com/how-an-ic-disc-can-be-used-to-defer-tax-on-commissions-related-to-10-million-of-export-sales-per-year/?utm_source=rss&utm_medium=rss&utm_campaign=how-an-ic-disc-can-be-used-to-defer-tax-on-commissions-related-to-10-million-of-export-sales-per-year
In response to the WTO's ruling, the United States enacted the Interest Charge-Domestic International Sales Corporation (“IC-DISC”) export ...
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38 Foreign-Derived Intangible Income and How It Relates to GILTI
https://pro.bloombergtax.com/brief/foreign-derived-intangible-income/
How do the IC-DISC and FDII tax incentives compare? ... a portion of income not otherwise treated as subpart F income if a CFC has business ...
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39 ADVANCED TAX PLANNING TECHNIQUES
http://www.miamilegalresources.com/files/115135307.pdf
less certain, with approximately half of the states following the federal tax treatment and the remainder taxing IC-DISCs. As a practical matter the IC-DISC ...
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40 A Tax Journal - Texas Tax Section
https://www.texastaxsection.org/Content/Newsletters/TTL_WINTER_2017.pdf
State and Local Tax Committee ... of care in their state. ... As a result, the IC-DISC does not pay tax on the commission.
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41 Summary of IC-DISC Tax Benefits - Miller Canfield
https://www.millercanfield.com/resources-392.html
An IC-DISC is a C-corporation that elects IC-DISC treatment under U.S. tax law. An IC-DISC does not have to own any tangible assets or have a ...
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42 IC-DISC Tax Law Challenges: Structuring and Planning ...
http://media.straffordpub.com/products/ic-disc-tax-law-challenges-structuring-and-planning-techniques-to-maximize-federal-tax-savings-2016-05-17/presentation.pdf
Corporation incorporated within the United States. • Single class of stock. • Stock par value > $2,500. • Elect to be treated as IC-DISC ...
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43 2022 year-end tax considerations for business
https://laporte.com/wp-content/uploads/2022/11/LaPorte_Whitepaper_2022-year-end-tax-considerations-for-business.pdf
independent accounting and consulting firms in the United States. ... which elects to be treated as an IC-DISC within the first 90 days of the tax year for ...
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44 Instructions for Form 1120-IC-DISC - (Rev. December 2008)
https://www.unclefed.com/IRS-Forms/2010/i1120icd.pdf
An IC-DISC is a domestic corporation that ... be organized under the laws of a state or. Penalties . ... Its election to be treated as an IC-DISC.
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45 Piercing the IC-DISC veil for a more rigorous regime of ...
http://kluwertaxblog.com/2015/09/02/piercing-the-ic-disc-veil-for-a-more-rigorous-regime-of-international-dividend-taxation/
The tax paid on dividends in the United States according to Treaty rules should not ... The IC-DISC treatment is nonetheless conditional.
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46 Chapter Tax 2 INCOME TAXATION, RETURNS, RECORDS ...
https://docs.legis.wisconsin.gov/code/register/1996/480b/remove/tax2-partial.pdf
state of residence imposes an income tax on the personal ... This treatment shall ... federal annual information return, form 1120-IC-DISC, is.
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47 IC-DISC and United States Exporting of Computer Software ...
https://www.taxconnections.com/taxblog/ic-disc-and-united-states-exporting-of-computer-software-internet-sales-and-licenses/
What is the definition of “Export Property” that will qualify for DISC treatment? Answer: Export property means property: Manufactured, produced ...
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48 Tax Incentive Strategy for US Exporters: Interest-Charge DISC ...
https://aitc.ua.edu/wp-content/uploads/IC-DISC_Presentation_AITC_12-13.pptx
Potential benefits of the IC-DISC with an example. Federal & State Taxation. Includes Mississippi, Alabama, and Florida treatment of IC-DISC ...
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49 Proposed Build Back Better Act contains key tax provisions
https://www.plantemoran.com/explore-our-thinking/insight/2021/09/build-back-better-act-bill-text-released-by-house-of-representatives
Limitations on foreign-owned DISC — Distributions from an IC-DISC to a foreign owner would be treated as income effectively connected with a ...
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50 IC-DISC Still Providing Big Tax Benefits - CPA Firm Boston MA
https://www.fjvtax.com/blog/
Most IC-DISC taxpayers that I work with use the 4% of export gross ... in the applicable state statutes, may result in different treatment ...
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51 State of Californias Franchise Tax Board provides guidance ...
https://wtpadvisors.com/state-of-californias-franchise-tax-board-provides-guidance-on-ic-disc.php
What is the proper treatment for California tax purposes of transactions between corporations designated as an IC-DISC for federal purposes, and its owners?
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52 Frequently Asked Questions about the IC DISC | HubSpot
https://cdn2.hubspot.net/hub/23880/file-13478265-pdf/docs/frequently_asked_questions_about_the_ic_disc.pdf
It is a tax incentive available to a privately-held US manufacturer or distributor that delivers products outside of the United States. 2. I sell many of my ...
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53 26 U.S. Code § 995 - Taxation of DISC income to shareholders
https://www.law.cornell.edu/uscode/text/26/995
Such indebtedness owed to a DISC shall be treated as an asset but shall not be treated as ... freight insurance, State and local income and franchise taxes, ...
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54 H.R. 6264, THE"TAX TECHNICAL CORRECTIONS ACT OF ...
https://www.govinfo.gov/content/pkg/CPRT-109WPRT31496/html/CPRT-109WPRT31496.htm
84 Riley, Thomas, New York State Society of Certified Public Accountants, ... Current Law Provisions The IC-DISC provisions of Code sections 991-997, ...
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55 Proposed Collection; Comment Request for Forms 1065, 1066 ...
https://www.federalregister.gov/documents/2022/09/28/2022-20962/proposed-collection-comment-request-for-forms-1065-1066-1120-1120-c-1120-f-1120-h-1120-nd
Form 1120-IC-DISC, Interest Charge Domestic International Sales ... *Form 4876-A, Election to Be Treated as an Interest Charge DISC.
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56 District of Columbia Tax Expenditure Report
https://cfo.dc.gov/sites/default/files/dc/sites/ocfo/publication/attachments/2014%20Tax%20Expenditure%20Report_0.pdf
states with an income tax use federal adjusted gross income as the ... The parent company pays the IC-DISC a tax-deductible commission for.
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57 Instructions for Form N-30, Rev 2021 - Hawaii.gov
https://files.hawaii.gov/tax/forms/2021/n30ins.pdf
its presence in the State and to report their as- sets and revenues annually. ... mailing treated as timely filing/paying rule.” The ... 1120-IC-DISC.
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58 JCT Bluebook Template - Joint Committee on Taxation
https://www.jct.gov/CMSPages/GetFile.aspx?guid=d1071964-144b-492c-ab99-81b1c376232d
Clarification of treatment of DISC gains and distributions of ... or possessions of the United States for any taxable year and limits the ...
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59 785-296-2435 FAX - Kansas Legislature
http://www.kslegislature.org/li_2018/b2017_18/committees/ctte_h_tax_1/documents/testimony/20180321_01.pdf
Many states are treating GILTI as Federal Taxable Income. ... IC-DISC and former DISC dividends not included on line 1, 2, or 3.
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60 Reducing the Tax Impact on the Sale of Your Business
https://www.bnymellonwealth.com/articles/strategy/reducing-the-tax-impact-on-the-sale-of-your-business.jsp
... to help protect the value of a business from state and federal income tax as ... An IC-DISC is an entity created to enable exporters to convert ordinary ...
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61 2021 Corporation Franchise Tax Return (M4) Instructions
https://www.revenue.state.mn.us/sites/default/files/2022-02/m4_inst_21.pdf
information concerning Minnesota state tax laws or rules. ... other than those treated as C corporations for federal income tax purposes, ... 1120-IC-DISC.
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62 Commission Payments to IC-DISC Recharacterized as Non ...
https://www.natlawreview.com/article/commission-payments-to-ic-disc-recharacterized-non-deductible-dividends
Commission Payments to IC-DISC Recharacterized as Non-Deductible ... the payment of DISC dividends to a Roth IRA cannot be treated as excess ...
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63 How a Producer's Loan Can Enhance IC-DISC Benefits - KLR
https://kahnlitwin.com/blogs/tax-blog/how-a-producers-loan-can-enhance-ic-disc-benefits
An IC-DISC provides two types of tax benefits. First, it converts ordinary income into tax-advantaged qualified dividend income. Second, it ...
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64 Exporters Can Reduce Taxes with IC-DISC Tax Planning ...
https://www.linkedin.com/pulse/exporters-can-reduce-taxes-ic-disc-tax-planning-a-chris-ostler-cpa
Elects to be treated as an IC-DISC;; Maintains of a separate bank account;; Keeps annual accounting records;; Files annual income tax returns; ...
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65 The IC-DISC – A Major US Export Tax Incentive
https://www.kelleydrye.com/News-Events/Publications/Client-Advisories/The-IC-DISC-%E2%80%93-A-Major-US-Export-Tax-Incentive
By changing the tax treatment of dividend income in 2003, Congress unintentionally created the IC-DISC tax arbitrage opportunity, ...
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66 Could You Benefit From Establishing an IC-DISC - CSH
https://www.cshco.com/articles/could-you-benefit-from-establishing-an-ic-disc/
To qualify for an IC-DISC, exporters need to meet a number of IRS criteria, including being incorporated in one of the 50 states or District of Columbia, ...
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67 A Lawyer's Guide - Maximum Asset Protection
https://maximumassetprotection.com/uploads/articles/Jacob_Article_Spring_2015.pdf
State taxation is less certain, with approximately half of the states follow ing the federal tax treatment and the remainder taxing. IC-DISCs.
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68 IC-DISC: The Big Tax-Break for Exporters - Forbes
https://www.forbes.com/sites/deanzerbe/2011/03/29/ic-disc-the-big-tax-break-for-exporters/
ordinary income (top rate 39.6% -- plus 0.9% health care tax) -- so the underlying basis for the IC-DISC benefit stays in place.
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69 C Corporation Income Tax
https://www.dfa.arkansas.gov/images/uploads/incomeTaxOffice/CorporationIncomeTax_Instructions.pdf
of this State, or having income from Arkansas sources as defined in ACA 26-51-205 must file an income tax ... D.I.S.C and F.S.C. Corporations are treated.
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70 Domestic international sales corporation - Wikipedia
https://en.wikipedia.org/wiki/Domestic_international_sales_corporation
The domestic international sales corporation is a concept unique to tax law in the United States. ... Today, shareholders of a DISC continue to receive reduced income tax ...
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71 Election To Be Treated as an Interest Charge DISC - OMB.report
https://omb.report/icr/201401-1545-006/doc/44698001.pdf
City or town, state, and ZIP code. D Name of person who may be called for information: (optional). C. Tax year of IC-DISC: Must use tax year of shareholder ...
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72 2018 PA Corporate Net Income Tax - CT-1 Instructions (REV ...
https://www.revenue.pa.gov/FormsandPublications/FormsforBusinesses/CorporationTax/Documents/2018/2018_rev-1200.pdf
Corporations requesting extra-statutory treatment beyond that provided by law; ... confirming with the PA Department of State, that the corporation.
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73 Tax Law Alert: Oregon's 2013 Special Legislative Session ...
https://www.stoel.com/tax-law-alert-oregons-2013-special-legislative-session
Instead, Oregon law treated an IC-DISC in the same manner as any other corporation and disregarded transactions between a taxpayer and an ...
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74 corporate income, franchise, and insurance tax bulletin | nc.gov
https://files.nc.gov/ncdor/documents/files/2017_corporate_income_franchise_and_insurance_tax_bulletins.pdf
activities in the State, remedies include requiring separate accounting ... conducted within this State if such DISC is not subject to a tax ...
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75 INDIANA - State Forms Online Catalog
https://forms.in.gov/Download.aspx?id=12112
corporation if it elects to be treated as a homeowners association. It is not considered a nonprofit ... Filing federal Form 1120-IC-DISC, file: Form IT-20.
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76 Everything That You Need To Know About International Tax ...
https://freemanlaw.com/everything-that-you-need-to-know-about-international-tax-penalties/
Penalties related to returns, however, are generally treated as taxes and governed ... An IC-DISC must file an annual U.S. tax return even though it pays no ...
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77 Other News & Info Archives - Page 33 of 73 - Whalen CPA
https://www.whalencpa.com/category/other-news-info/page/33/
The tax treatment of investment income varies, and not just based on ... Essentially, an IC-DISC allows you to convert ordinary income taxed at rates as ...
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78 information statement - Glacial Lakes Energy
http://www.glaciallakesenergy.com/documents/Full_GLCP_Information_Statement.pdf
Q10: How will GLCP and I be taxed on the IC-DISC Transaction? A: The value of the capital units of the Holding Company that you receive will be treated as a.
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79 The Uneasy Marriage of Export Incentives and the Income Tax
https://www.journals.uchicago.edu/doi/pdf/10.1086/654730
2.1 Subsidy by Exemption of Income: FSCs and IC-DISCs. Firms that export goods from the United States are entitled to do so in a legally roundabout.
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80 APPLICATION OF SECTION 199A TO DOMESTIC ...
https://www.morganlewis.com/-/media/files/publication/outside-publication/article/2018/jct-18-05-03-august.ashx
item for which there was substantial authority for the tax treat- ... for an IC-DISC employing the “50-50” combined taxable in-.
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81 Application of Section 199A to Domestic Taxpayers Engaged ...
https://www.carltonfields.com/getmedia/7148303e-c063-4e1d-b97e-89e03bc70d63/Application-of-Section-199A-to-Domestic-Taxpayers
conduct of a trade or business within the United States. ... A U.S. corporation may elect to be treated as an IC-DISC so long as it complies with certain ...
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82 Tax Policy Changes - Oregon State Legislature
https://www.oregonlegislature.gov/lro/Documents/HB%203601%20Research%20Report.pdf
Recognize IC-DISC, allow subtraction for ... 2 With the implementation of the Affordable Care Act, the federal threshold for deducting ...
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83 KPMG report: “Build Back Better Act” tax proposals in House bill
https://assets.kpmg/content/dam/kpmg/us/pdf/2021/11/tnf-bbba-tax-proposals-pending-house-bill-nov11-2021.pdf
to the modification to the deduction for state and local taxes. ... Clarification of treatment of DISC gains and distributions of certain ...
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84 Agenda - UC Davis School of Law
https://law.ucdavis.edu/sites/g/files/dgvnsk10866/files/media/documents/Income-Whitney-4.pptx
In 1974, California joined a number of states in enacting the Multistate Tax Compact as ... Tax Treatment of Transactions between IC DISCS and their Owners.
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85 attaining us effectively connected income in
https://www.uakron.edu/law/lawreview/taxjournal/atj21/docs/lebron1.pdf
United States-Tax Treatment of “Foreign Sales Corporations. ... either repeal or modify the FSC rules.77 The IC-DISC was not a target of.
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86 build-back-better-tax-proposals-approved-by-the-house-ways ...
https://www.mayerbrown.com/-/media/files/perspectives-events/publications/2021/09/build-back-better-tax-proposals-approved-by-the-house-ways--means-committeev2.pdf
To paraphrase Frank Zappa,1 “[t]he United States is a nation of laws ... distributions to a foreign shareholder of an IC-DISC are treated as.
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87 Earnings and profits computation practice guide - eGrove
https://egrove.olemiss.edu/cgi/viewcontent.cgi?article=1063&context=aicpa_assoc
current E&P of a prior year) may result in a change in the tax treatment of intervening ... IC-DISC and form er DISC dividends not included on lines 1, 2, ...
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88 24 May 2018 External T.I. 2017-0710641E5 - Interest Charge ...
https://taxinterpretations.com/cra/severed-letters/2017-0710641e5
Reasons: The IC-DISC is liable to tax in the U.S. by reason of its place ... an IC-DISC would be considered a resident of the United States ...
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89 2017 Tax Cuts and Jobs Act offers mixed results for the ...
https://taxnews.ey.com/news/2017-2200-2017-tax-cuts-and-jobs-act-offers-mixed-results-for-the-technology-sector
DISC / IC-DISC: The Tax Cuts and Jobs Act adds Section 951A to prevent ... under Section 951(a) is treated the same as subpart F income for ...
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90 International Tax Strategies - Reduce Your Tax Rate! - RJI CPAs
https://rjicpas.com/wp-content/uploads/2018/07/OCBJ-International-Tax-Strategies-Article.pdf
corporations, a captive insurance company and/or establishing an IC-DISC. ... in U.S. corporate and tax law of treating corporations as entities separate ...
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91 description of the chairman's amendment in the nature
https://www.novoco.com/sites/default/files/atoms/files/jcx-43-21-description-chairman-amendment-09152021.pdf
Clarification of treatment of DISC gains and distributions of certain ... foreign country or possession of the United States which is ...
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92 IC-DISC Tax Services - Withum
https://www.withum.com/service/international-services/ic-disc/
An Interest Charge Domestic International Sales Corporation (IC-DISC) is a tax-exempt, domestic corporation set up to receive commissions on qualified ...
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