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IC Disc vs. Other Tax Planning Tools

 23 April, 2024
Choosing the Right Tool: Comparing IC Discs with Other Tax Planning Structures While IC Discs offer unique tax benefits for exporters, it’s essential to consider alternative tax planning tools such as foreign sales corporations (FSCs) or domestic international sales corporations (DISCs). Each structure has its advantages and limitations, and the optimal choice depends on the […] Read More »

IC Disc Compliance and Reporting

 23 April, 2024
Navigating Compliance: Ensuring IC Disc Tax Benefits through Proper Reporting Maintaining compliance with IC Disc regulations is crucial for companies to ensure the continued tax benefits of this structure. Adhering to specific compliance and reporting requirements is essential for companies with an IC Disc entity to avoid penalties and maintain eligibility for tax benefits. Filing […] Read More »

Tax Savings Strategies with IC Disc

 23 April, 2024
Unlocking Tax Benefits: Strategies to Maximize Savings with IC Disc Implementing an Interest Charge Domestic International Sales Corporation (IC Disc) can provide significant tax planning opportunities for companies engaged in exporting. Understanding and leveraging tax-saving strategies with IC Discs is essential for maximizing the benefits of this unique tax structure. Maximizing Deferral of Export Income: […] Read More »

IC DISC Qualification Criteria

 23 April, 2024
Unlocking Tax Benefits: Understanding IC DISC Qualification Criteria for Exporters Establishing an Interest Charge Domestic International Sales Corporation (IC DISC) can provide valuable tax benefits for U.S. companies engaged in exporting goods or services. Understanding the qualification criteria for IC Discs is essential for businesses looking to leverage these tax incentives. Qualifying Export Activities: To […] Read More »

IC DISC Benefits for Exporters

 23 April, 2024
Maximizing Tax Savings: The Advantages of Utilizing IC Discs for Exporters Interest Charge Domestic International Sales Corporations (IC DISCs) offer significant tax benefits for U.S. companies engaged in exporting U.S. manufactured, produced, grown or extracted goods or architectural and engineering services. Understanding the advantages of utilizing IC DISCs can help exporters optimize their tax positions […] Read More »

Understanding IC DISC Basics

 23 April, 2024
Demystifying IC DISC: A Primer on Interest Charge Domestic International Sales Corporations Interest Charge Domestic International Sales Corporations (IC DISCs) are a valuable tax planning tool for U.S. companies involved in exporting U.S. manufactured, produced, grown or extracted goods or architectural and engineering services. Understanding the basics of IC DISCs is essential for businesses looking […] Read More »

OECD vs. U.S. Profit-Split Method Guidance Differences and Similarities

 24 April, 2023
Our second article in a series on the profit split method (“PSM”), “The Profit-Split Method: A Comparison of U.S. and OECD Guidance,” published in Tax Notes International on April 24, 2023. We describe what multinational enterprises (MNEs) must understand to navigate the differences and similarities between the U.S. Treasury’s transfer pricing regulations (“U.S. Regs”) and the […] Read More »

Introducing the Profit Split Method – To Apply or Not to Apply, This is a BEPS Question.

 27 March, 2023
Guy Sanschagrin and Doug Schwerdt’s article “Introducing the Profit Split Method – To Apply or Not to Apply, This is a BEPS Question” ran in the March 27, 2023, issues of Tax Notes International and Tax Notes Federal. The article examines nuances of the profit split method (PSM), including its origins and when it should […] Read More »

Was the right Transfer Pricing method used in Medtronic vs. Commissioner?

 29 August, 2022
Guy Sanschagrin, CPA/ABV was asked to weigh in about the recent decision in Medtronic v. Commissioner and whether the Court applied the right transfer pricing solution to the profit allocation of the case. In Tax Note’s August 23, 2022, article “Medtronic’s Unspecified Method Raises Specific Questions”, written by Alexander F. Peter, Sanschagrin states that a more […] Read More »

Take A Break from Your Daily Grind with our Six-Question SALT Transfer Pricing Quiz!

 14 April, 2022
The 2022 SALT Transfer Pricing Quiz is anything but your run-of-the-mill test of knowledge. The Quiz, based on our January 2022 two-part Tax Notes State article, “SALT Transfer Pricing — What You Need to Know,” contains everything you need to know to swiftly grind out correct answers to the six multiple-choice questions and win a red, white, […] Read More »

The UK enacts new rules requiring disclosure of tax treatments

 7 March, 2022
The UK has enacted new rules requiring disclosure of tax treatments where the correctness of the position is uncertain. The rules are effectively a requirement that taxpayers must provide HMRC with a list of tax treatments that HMRC might wish to challenge. The rules are not specifically targeted at transfer pricing, but it seems likely that […] Read More »

Now is Not the Time to Ignore Transfer Pricing

 2 August, 2021
By Scott Smaistrla COVID-19 necessitates a reassessment of the existing transfer pricing paradigms of Multinational Enterprises (MNEs). Supply chain disruptions and changes in consumer demand resulting from the COVID-19 pandemic and global recession are impacting virtually all major industries. These disruptions erode profits and will require MNEs to adjust transfer pricing approaches. MNEs also face […] Read More »

Apple, the EU, and Country by Country Reporting

 22 July, 2021
Apple, the EU, and Country by Country Reporting The story of Apple Inc. and the European Commission is well known by now. Back in August of 2016 the EU’s Competition Commission announced their ruling that Ireland had given Apple an unfair sweetheart deal allowing it to pay less tax in Ireland than it should, and […] Read More »

Master File / Local File Transfer Pricing Documentation FAQs

 22 July, 2021
Master File / Local File Transfer Pricing Documentation FAQs A client recently asked me to explain the “Master File / Local File” (“MF/LF”) system of transfer pricing documentation that is being adopted by an increasing number of countries. So I thought that there was no time like the present to put together a basic overview […] Read More »

BEPS Action 13 Update

 22 July, 2021
BEPS Action 13 Update Earlier this year, our blog “Master File / Local File Transfer Pricing Documentation FAQs” provided an overview of what a Master File / Local File (MF/LF) system looks like along with practical considerations on implementing and maintaining the MF/LF system. As of today, our blog pops up at the top of […] Read More »

New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles

 22 July, 2021
New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles The Tax Cuts and Jobs Act of 2017 (the Act) brought sweeping changes to the international tax landscape, including the transfer pricing arena. Intangible property is at the core of many of these changes. The impact of the new provisions generally furthers the trend of […] Read More »

Six Time-Tested TPEP Takeaways

 2 February, 2021
While we have periodically written about the Transfer Pricing Examination Process, Publication 5300 (TPEP) and its predecessor, the Transfer Pricing Audit Roadmap, for this blog post we revisited the TPEP to determine how well this IRS guidance and our initial insights on it have withstood the test of time relative to our field-based transfer pricing (“TP”) experience […] Read More »

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