Understand the ideal mechanisms required to form and maintain an IC-DISC.
An Interest-Charge Domestic International Sales Corporation regime, known as an IC-DISC, is a federal tax export incentive regime. Under the regime, U.S. companies that export goods and services to foreign countries are permitted to enjoy certain benefits, provided certain conditions are met. An IC-DISC creates the opportunity to tax a portion of export-related profits at lower tax rates and to potentially defer export-related income to future tax years. This topic will provide you the ideal mechanisms required to form and maintain an IC-DISC. You will also learn the requirements of commission payments of the IC-DISC based upon gross receipts and the qualifying assets test. This material will discuss the specific benefits of the IC-DISC, including the potential benefit of qualified dividend rates on commissions paid to its shareholders. The topic will also provide and discuss structuring opportunities based upon common business types, including ideal S-Corporation and C-Corporation IC-DISC structuring options. Additionally, the information will cover the effect of the Tax Cuts and Jobs Act on the potential IC-DISC benefit and related tax planning opportunities. Finally, President Biden's tax plan may significantly impact the IC-DISC benefit and alter traditional structuring options. Such potential impacts will be explored as well.
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Mario A. de Castro
- Managing director with Crowe LLP’s Washington, D.C. office
- For more than 15 years, he has been counseling both private and public companies in the areas of corporate and international tax and related international corporate and business matters
- Experience includes advising closely held enterprises with ongoing international operations and expanding overseas; his experience has included advising on merger and acquisition due diligence; supply chain and intellectual property planning, ongoing structure analysis; and intercompany transaction maintenance for companies operating throughout the world
- He has written articles and presented numerous times at seminars in the U.S., Europe, and Latin America on international tax matters, and related industry-specific topics ranging from mergers and acquisitions, supply chain planning, life sciences industry-specific tax issues, U.S. tax reform, cryptocurrency, and the digital economy and e-commerce
- He is licensed to practice law in the State of Florida
- Member of the Florida Bar Association (Tax Section), International Fiscal Association (D.C. Branch), American Bar Association (Tax Section)
- LL.M. degree in taxation, international tax certificate, University of Miami School of Law; J.D. degree, Temple University School of Law; B.A. degree in international relations and Latin America studies and economics, Tulane University
- Can be contacted at 202-552-8021, [email protected] or at https://www.linkedin.com/in/mariodecastro
- Global Tax Services manager based in Crowe LLP’s Chicago office
- Provides compliance and consulting services to multinational companies in various industries
- Over 8 years of experience helping companies with their global compliance and consulting needs
- Has also held a role in Crowe’s National Tax Office and has written numerous articles and highlights on International Tax
- Extensive experience with managing and executing on large engagements for multinational companies
- Certified Public Accountant (CPA) - Illinois
- B.S. degree in accounting and finance, Illinois State University
- Senior manager based in Crowe LLP’s New York City office and provides international tax consulting and compliance services to multinational businesses
- More than 9 years of experience helping global companies with tax consulting, compliance, and financial reporting matters
- Previously held both in-house and consulting positions in both international and federal taxation
- Has extensive experience with international tax planning, mergers and acquisitions, and tax compliance, including lead roles managing and executing large compliance engagements for major multinational organizations
- Certified Public Account (CPA) – New Jersey
- B.S. degree in accounting, Rutgers University
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