 |
 EXPORT TAX BENEFITS
BASED ON MANY YEARS OF EXPERIENCE IN PROVIDING EFFECTIVE, PROFESSIONAL EXPORT TAX AND FINANCE MANAGEMENT SERVICES, EXPORT ASSIST WILL HELP DESIGN, IMPLEMENT AND MANAGE THE EXPORT TAX BENEFIT PROGRAM THAT BEST MEETS YOUR OBJECTIVES.
Whether you are public or private, large or
small, you could benefit from the:
And, Export Assist continues to perform Foreign
Sales Corporation (FSC) Management and Termination Services for
regular and long-term lease FSCs that have remained active for tax
and compliance purposes.
If you have any questions, please contact Ms. Tamara Crews,
Vice President – Professional Markets, directly at 800-894-8366 or tcrews@exportassist.com.
IC-DISC and VIEXCO
The following chart highlights
the structure and benefits that can be received with an IC-DISC
and a Virgin Islands Export Corporation (VIEXCO).
IC-DISC |
VIEXCO |
Structure:
- Domestic C corporation
- Benefits begin upon incorporation
- IC-DISC can own a Foreign International
Sales Corporation (FISC)
- 100% safe harbor commission or buy/sell
- Not a taxable entity
|
Structure:
- Controlled foreign corporation (CFC)
- Benefits begin upon incorporation
- Foreign presence
- Services or buy/sell
- Entity with virtually no tax
|
Benefits:
- Dividends - 15% tax rate for individuals
- Deferral with $10 million annual
revenue limit
- Low-cost working capital for export
growth and R&D (R&D tax credits applicable)
- Increased cash flow for exporter
- Lower effective tax rate
- Reduced taxable base at exporter level
- Elimination of double taxation in C corporations
- Protection of IRC safe harbor commission provisions
|
Benefits:
- Dividends - 15% tax rate for individuals
- Unlimited deferral
- Low-cost working capital for export growth
- Increased cash flow for exporter
- Lower effective tax rate
- Use of foreign tax credit carryforwards
- Use of trapped Section 956 funds in the U.S. without Subpart F exposure
|
Who benefits
the most:
- Small to medium, private exporters
|
Who benefits
the most:
- Medium to large, private and public exporters
|
Recovery of ETI Benefits
Although ETI was repealed
in 2006, exporters might be able to recover Extraterritorial Income
Exclusion benefits
for open tax years 2005 and 2006 as long as they did not have
an active IC-DISC in those years. This could be of interest to
the majority of exporters who never applied for ETI benefits and
to those
with annual foreign trading gross receipts in excess of $5,000,000
who only applied for the minimum benefit amount.
FSC Management and Termination Services
Export Assist continues its foreign sales corporation management
services to keep your FSC active and in good standing, thereby
allowing you and your tax advisor to facilitate future dividend
declarations, tax refunds, tax amendments, redeterminations and
outstanding audits or to maintain FSC-related activities for long-term
lease FSCs. Once these purposes have been fulfilled, Export Assist
will terminate or dissolve your FSC.
For more information, please contact Ms. Tamara Crews, Vice President
- Professional Markets, at 800-894-8366 or tcrews@exportassist.com.
|
