Scenario:
ABC Manufacturing is a U.S. company that manufactures high-quality industrial equipment. ABC’s annual revenue from exporting these goods abroad is $10 million. They decide to establish an IC-DISC to take advantage of U.S. tax incentives for exporters.
ABC Manufacturing is the parent company.
ABC-ICD is the newly formed IC-DISC.
Step 1: Setting Up the IC-DISC
ABC Manufacturing sets up the IC-DISC, which is a C Corporation. The IC-DISC is a separate entity The IC-DISC then earns a “commission” on the operating company’s export sales based on the greater of
50% of net income on sales of qualified export property or 4% of gross receipts from sales of qualified export property or in some cases an arm’s length transfer pricing is used.
Step 2: Income Transfer to IC-DISC
Let’s assume ABC Manufacturing sells the goods for $10 million and enjoys a profit on these export sales of $2 million , and this is where the tax advantages will come into play.
Step 3: How the IC-DISC Generates Tax Savings
IC-DISC benefits come primarily from how its income is taxed compared to regular corporate income.
Without an IC-DISC:
If ABC Manufacturing did not use an IC-DISC and simply kept the income from export sales, it would be subject to corporate tax rates (the C Corporation tax rate).The current corporate tax rate is 21%.
With an IC-DISC:
The IC-DISC is a pass-through entity for tax purposes, so it doesn’t directly pay corporate tax. Instead, the commision ($1 million) is distributed to ABC Manufacturing as qualified dividends, which are taxed at a lower rate. These dividends benefit from the 65% dividend exclusion for a C Corporation parent. So in essence the tax rate is 35% of 21% on the return dividend or a 13.65% savings.

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