Foreign Derived Intangible Income (FDII) is a tax provision established by the Tax Cuts and Jobs Act (TCJA) of 2017 (§250(b)) to incentivize U.S. companies to earn income from exporting goods and services, while discouraging profit shifting to lower-tax jurisdictions.… Read More

A U.S. person owning shares in a foreign corporation may be subject to GILTI (Global Intangible Low-Taxed Income) tax, but this depends on several factors related to your ownership in the foreign corporation.  Here’s what you need to consider…… Read More

Introduced by Congress in 1971 to stimulate U.S. exports, Interest Charge Domestic International Sales Corporations (IC-DISCs) remain a robust tax planning tool. They offer substantial permanent tax savings and deferral opportunities for American companies, underscored by recent tax reforms preserving preferential treatment for qualified dividends and long-term capital gains.… Read More

Factoring accounts receivable (A/R) via an IC-DISC presents a powerful avenue for companies engaged in exporting to amplify their tax savings. Here’s an overview of how this strategy operates at a high level:… Read More