ic-disc 2.0: moving beyond the basics to pricing...

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IC-DISC 2.0: Moving Beyond

the Basics to Pricing Commissions and

Structuring Complex Corporate Entities Designing Commission Strategies, Utilizing Trusts, and Setting Up Distributor Companies

Today’s faculty features:

1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific

THURSDAY, FEBRUARY 2, 2017

Presenting a live 90-minute webinar with interactive Q&A

Mark C. Gasbarra, CPA, National Managing Director, Forte International Tax, Evanston, Ill.

Robert J. Misey, Jr., Shareholder, Reinhart Boerner Van Deuren, Chicago and Milwaukee

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35.

FOR LIVE EVENT ONLY

IC-DISCs: Structuring to

Maximize Tax Benefits

Presented by

Robert Misey, Esq.

Chair, International Department

Reinhart Boerner Van Deuren, s.c.

(312) 207-5466; (414) 298-8135

[email protected]

©2017 All Rights Reserved Reinhart Boerner Van Deuren s.c.

Today's Discussion Topics

• Tax benefits of the IC-DISC

• Tests to qualify as an IC-DISC

• Requirements—manufacturing, destination, content

• Determining and maximizing the IC-DISC benefit

• A multitude of structuring techniques, including

– The use of trusts for exporters whose ownership percentage

changes

– The use of IC-DISCs to compensate certain employees

5


Introduction to IC-DISC

• Formation of the IC-DISC

– A single class of stock

– A minimum par value of $2,500

– Elect to be an IC-DISC with a Form 4876-A

6


Introduction to IC-DISC (cont.)

• Taxation of an IC-DISC and its shareholders

– An IC-DISC is not subject to corporate tax

– When the IC-DISC pays a dividend, its owners will

pay tax at a 20% rate

– If the manufacturing entity is a flow-through entity,

the tax savings are 20 percentage points

– If the manufacturing entity is a C corporation, the

tax savings are 28 percentage points

7


The Tests to Qualify as an IC-DISC

• Qualified Export Receipts Test

• Qualified Export Assets Test

8


The Tests to Qualify as an IC-DISC (cont.)

• 95% of its gross receipts must constitute

qualified export receipts

– Sales of export property

– Rents for use of export property outside the

United States

– Services related to exports

– Engineering or architectural services for

construction projects abroad, and

– Commissions

9


Example 1

Sales Produce Gross Receipts

10

IC-DISC


Example 2 Services Produce Gross Receipts

11

IC-DISC


Example 3 Architectural Services Produce

Gross Receipts

12

IC-DISC


The Tests to Qualify as an IC‐DISC

• 95% of the assets of the IC-DISC must be

qualified export assets

– Temporary investments

– Export property

– Accounts receivable

– Loans to producers

13


Example 4 Working Capital as Qualified Export Assets

14

IC-DISC


Example 5 Export Property as Qualified Export Assets

15

IC-DISC


Qualification as Export Property

• The property must be manufactured in the

U.S. by a person other than the IC-DISC

• The export property must be held primarily

for use outside the U.S.

• The property must have a maximum of 50%

foreign content

16


Qualification as Export Property (cont.)

• Property is manufactured within the U.S. if

either

– U.S. conversion costs incurred constitute 20% of

the cost of goods sold

– There is a substantial transformation in the United

States, or

– The operations in the U.S. are generally

considered to constitute manufacturing

17


Example 6

Generally Considered to Constitute

Manufacturing

18

IC-DISC USAco

commission

US

sunglass components

Foreign

U.S.

sunglasses

Exports

US

IC-DISC USAco


Qualification as Export Property

• The Destination Requirement

– The destination test

requires being held

for use outside the

United States

19


Example 7

Satisfying the Destination Test

20

IC-DISC


Example 8

No Further U.S. Manufacturing

21

IC-DISC

Big3co

Familyco


Example 9

22

P

US

IC-DISC


Qualification as Export Property (cont.)

• The Maximum of 50% Foreign Content

Requirement

– No more than 50% of the fair market value of

export property may be attributable to the fair

market value of imported articles

– The fair market value of the foreign content is

determined by its dutiable value

23


Determining the IC-DISC Benefit

• The commission is the greater of

– 4% of the qualified export receipts

– 50% of the combined taxable income, or

– The arm's-length amount determined under the transfer pricing principles of Section 482

24


Example 10

4% of the Qualified Export Receipts

25

IC-DISC

US


Example 11

50% of Combined Taxable Income

26

US

IC-DISC

Any tax advice included in this communication is not intended or written to be used, and it cannot be

used by any taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer.

© Forte International Tax, LLC All rights reserved. www.forteintax.com

Calculating IC-DISC Income

Mark C. Gasbarra

Strafford Webinar IC-DISC 2.0

February 2, 2017

29 29

Speaker Introduction

Mark Gasbarra, CPA

National Managing Director

Forte International Tax, LLC

Firm’s focus is delivering processes and tools, including

VantagePoint™, to help international businesses

minimize their global tax cost

Service areas include the full range of international tax

services including structuring, transfer pricing, foreign

tax credit utilization and U.S. manufacturing and export

tax incentives (“IC-DISC”)

Mark has worked with DISC’s since 1981 and has led

the export incentives practices of two of the Big-Four

accounting firms before forming Forte International Tax

Services in 2004

30 30

Topics of this Session

Maximizing IC-DISC Taxable Income

Related Supplier Methods

Administrative Pricing Rules

4% Gross Receipts

50% Combined Taxable Income

Arms Length Pricing - §482

Unrelated Supplier?

Calculating Combined Taxable Income

Commission versus Buy-Sell Transactions

Marginal Costing & No Loss Rules

Special topics

Case Study

31 31

IC-DISC History

1971: Domestic International Sales Corporation (DISC) regime

enacted

1984: DISCs are replaced with two separate provisions, Foreign Sales

Corporations (FSCs) and IC-DISCs

2000: FSCs repealed and replaced with Extraterritorial Income (ETI)

2004: ETI phased out and section 199 phased-in

32 32

Why Do We Care?

Bottom Line – Tax Savings!

Qualified DISC income is exempt from Federal income tax and

may be excluded from State income tax as well.

An IC-DISC is a domestic corporation so its dividends to qualified

shareholders are taxed at capital gains rates.

Goal: Maximize the DISC’s income and minimize the ordinary

taxable income of its related supplier.

33 33

DISC Income Options

Administrative pricing methods

– Available to allocate profits between a Related Supplier and an IC-DISC.

– This is the most common and will be the focus of our discussion.

Arm’s length profit calculation determined under IRC Section 482

– Applicable to transactions between related parties that are controlled by

the same interests.

Fully operational exporter of U.S. produced property entity

– Any supplier will do.

34 34

Related Party & Related Supplier

Related Party

– A person which is controlled directly or indirectly by the same interests as

the IC-DISC within the meaning IRC Section 482.

Related Supplier

– A related party which singly engages in a transaction directly the IC-

DISC.

Administrative Pricing Rules

– Only applicable to transactions between an IC-DISC and its related

supplier.

An IC-DISC may have different related suppliers with respect to

different transactions

35 35

Related Supplier Example

X owns all the stock of Y, a regular corporation, and of

Z, an IC- DISC

X sells a product to Y which is resold to Z

Only Y is the only related supplier of Z with respect to

this transaction and eligible for Administrative Pricing

If, however, X sells directly to Z and Y also sells

directly to Z, then, as to the transactions involving

direct sales to Z, each of X and Y is a related supplier

of Z.

36 36

Administrative Pricing Methods

4% Gross Receipts Method(s)

– Regular no-loss rule

– Special no-loss rule

50% Combined Taxable Income Method(s)

– Full Costing Combined Taxable Income (“FC-CTI”)

– Marginal Costing Combined Taxable Income (“MC-CTI”)

MC-CTI only considers direct costs (think about gross profit)

Limited to the overall profitability

Note that combined taxable income must always be determined.

37 37

What is “CTI” Anyway?

CTI is the limiting factor in determining DISC taxable income.

CTI is the combined taxable income of an IC-DISC and its

Related Supplier with respect to each qualified export

transaction.

In order to maximize the IC-DISC tax exempt income you first

maximize CTI.

In order to maximize CTI we must fully understand its

components.

– Qualified Export Receipts

– Directly Allocable Costs – with adherence to the Related Supplier’s

method of accounting

– Allocation and Apportionment of Deductions (Reg. 861-8)

38 38

Buy/Sell vs. Commission DISC

The same amount of DISC taxable income results under

either approach.

In a buy-sell transaction you first determine DISC

taxable income and then back into the transfer price.

Selection of a Buy/Sell or Commission can be made at

the transaction level.

39 39

How to Maximize CTI

Qualified export gross receipts are maximized by making sure to

pick up all available sources, including:

– Direct and Indirect Exports

– Component Sale

– Other components of gross receipts (broadly defined)

Cost of Goods Sold – must be consistent with the Related Supplier

method of accounting

Deductions – Section 861-8 allocation and apportionment

– Interest Expense - Assets

– Research & Development – Sales or Gross Income (5-year election)

– Other – considerable leeway here, based on a factual relationship

between the deduction and class of gross income

– Consistency among all operative sections of the IRC

40 40

What About TxT and Optimization?

The DISC regulations generally require the computation of

DISC taxable income individually for each export transaction

However grouping in accordance with industry trade or practice

is allowed (but generally not beneficial)

– Grouping for pricing; and or

– Grouping for Overall Profit Percentage

Best approach is a T x T pricing approach coupled with

Optimization by testing all available pricing and grouping

alternatives in addition to available allocation and apportionment

method using sophisticated software tools – this can make a big

difference where there is significant variability among the

various export transactions

41 41

Example 1

Example 1 Total Non-Export Export Trans 1

Export Trans 2 Grouped

Sales 400 200 100 100 200

COGS 250 100 90 60 150

Gross Profit 150 100 10 40 50

Expenses 120 80 8 32 40

Taxable Income 30 20 2 8 10

Profit Percentage 7.50% 10.00% 2.00% 8.00% 5%

IC-DISC Income

- 4% x QER 4.00 4.00 8.00

- Regular No-Loss Rule 2.00 8.00 10.00

Net 4% Method 2.00 4.00 8.00

- 50% x FC-CTI 1.00 4.00 5.00

Best Result 2.00 4.00 8.00

Observations Application of the regular no-loss rule

Grouping is beneficial in this case

All expenses are apportioned on a gross income basis

Export transaction #2 - Export profit of 8% results are same

42 42

What is Marginal Costing

It is a subset of the 50% combined taxable income method

Only considers direct costs (no 861-8 burden)

But, limited to the Overall Profit Percentage (“OPP”) multiplied

the qualified export receipts

The OPP is the taxable income (both domestic and export)

divided by all sales (both domestic and export)

– TI/Sales = OPP

Marginal Costing is always an option but only on Sales

Transactions

You are deemed to be discounting your exports sales in order to

penetrate foreign markets

43 43

Example 2



Sales 400 200 100 100 200

COGS 250 100 90 60 150

Gross Profit (MC-CTI) 150 100 10 40 50

Expenses 120 80 8 32 40



IC-DISC Income

- 4% x QER 4.00 4.00 8.00


Net 4% Method 2.00 4.00 8.00

- 50% x FC-CTI 1.00 4.00 5.00

- 50% x MC-CTI 5.00 20.00 25.00

- OPP Limitation 3.75 3.75 7.50

Net 50% MC Method 3.75 3.75 7.50

Best Result 3.75 4.00 8.00

Observations Marginal Costing boosts Export Trans 1 up to the OPP limit

Grouping is still beneficial

All expenses are apportioned on a gross income basis

No help from marginal costing on Export Trans #2

44 44

Example 3

Example 3 Total Non-Export Export Trans 1 Export Trans 2 Grouped

Sales 400 200 100 100 200

COGS 250 100 90 60 150


Expenses 120 80 8 32 40



IC-DISC Income

- 4% x QER 4.00 4.00 8.00


- Special No-Loss Rule 7.50 7.50 15.00

Net 4% Method 4.00 4.00 8.00

- 50% x FC-CTI 1.00 4.00 5.00

- 50% x MC-CTI 5.00 20.00 25.00


Net 50% MC Method 3.75 3.75 7.50

Best Result 4.00 4.00 8.00

Observations Marginal Costing boosts Export Trans 1 up to the OPP limit

Application of the Special No-Loss Rule allows full 4% on Trans 1 > 100% CTI

45 45

Example 4



Sales 400 200 100 100 200

COGS 250 100 90 60 150


Expenses 120 60 30 30 60

Taxable Income 30 40 -20 10 -10

Profit Percentage 7.50% 20.00% -20.00% 10.00% -5%

IC-DISC Income

- 4% x QER 4.00 4.00 8.00

- Regular No-Loss Rule -20.00 10.00 -10.00

- Special No-Loss Rule 7.50 7.50 15.00

Net 4% Method 4.00 4.00 8.00

- 50% x FC-CTI -10.00 5.00 -5.00

- 50% x MC-CTI 5.00 20.00 25.00


Net 50% MC Method 3.75 3.75 7.50

Best Result 4.00 5.00 8.00

Observations Now expenses are apportioned on relative Sales

Sales base increases the variability of profit

Now T x T = 9 which is and increase of 12.5% over grouping

The loss for Export Trans 1 is inconsequential

46 46

Key 861-8 Definitions

• Factual Relationships – between deductions and the “class of gross”

income to which they relate

• Allocation – normally a definite relationship will exist, in which case a

deduction is allocated to one or more classes of gross income

• Classes of Gross Income – not pre-defined but would include items

listed in IRC §61, including income derived from business, interest,

rents, royalties, dividends

• Apportionment – the process of spreading a deduction between the

statutory and residual groupings within a class

• Statutory Grouping – defined with respect to an operative section of

the IRC

• Residual Grouping – everything except the statutory grouping

• Operative Section – taxable income from a particular source, e.g.

qualified production activity income for DPAD

47 47

R&E Example (GI vs. Sales)

• Geographic Exclusive apportionment percentage

– N/A for DPAD

– GI Method is 25% vs. 50% for Sales Method

• Sales method focuses on 3-digit SIC Codes

– Product orientation may favor FTC

– Inclusion of controlled sales (CFC’s) – favors DPAD

– Inclusion on non-controlled sales (royalty payors) –

favors DPAD

• Numeric Example

48 48

Interest Expense

• Under IRC §864(e) and Treas. Reg. §1.861-9T

– Affiliated groups: allocate and apportion interest expense of each

member as if all members of such group were a single corporation.

• Foreign corporation treated as a member of affiliated group if:

– more than 50 percent of the gross income is effectively connected with the

conduct of a trade or business within the United States, and

– at least 80 percent of either the vote or value of all outstanding stock is

owned directly or indirectly by members of the affiliated group.

– Asset method must be used. May elect to determine the value of its

assets on the basis of either the:

• tax book value method.

• the alternative tax book value method, or

• the fair market value method.

– Tax-exempt assets not taken into account.

– Basis of stock in nonaffiliated 10-percent owned corporations

adjusted for earnings and profits changes.

49 49

Other Prescribed Relationships

• §1-861-8(e) Allocation and apportionment of

certain deductions. – Stewardship and controlled services.

– Legal and accounting fees.

– Income Taxes.

– Losses on the sale, exchange, or other disposition of property.

– Net operating loss deduction.

– Deductions which are not definitely related.

– Special deductions.

– Personal exemptions.

– Deductions for certain charitable contributions.

50 50

Supportive Deductions

• Under IRC §861-8T(B)(3) – Deduction may relate to other deductions, which can be more

readily allocated to gross income.

– Deductions may be allocated to all gross income or another broad

class of gross income and apportioned within that class using any

reasonable apportionment base.

– Deductions not definitely related to any class of gross income,

allocated and apportioned to all classes on a relative gross income

basis.

– §864(e)(6) and §1.861-14T require affiliated group apportionment

base, unless less than all members of affiliated group have gross

income in that class, in which case the base can include only the

members that have income in that class as part of the base.

51 51

Optimization Levers

Allocation and Apportionment

– Other than the prescribed methods for specific deductions, such as interest

and R&D, any method that is reasonable should be accepted.

– For example, sales, gross receipts, gross income, gross profit, cost of

goods sold, time spent, square footage, etc.

Pricing methods

– 4% gross receipts limited by either the regular or special no-loss rule

– 50% full cost or marginal cost limited by marginal cost combined taxable

income or the overall profit percentage limitation (OPP x QER)

Grouping alternatives

– Grouping for pricing and grouping for OPP

OPP Grouping

– May be broader than the pricing level (transaction or group)

52 52

Implementation Requirements

Key Data Elements

Legal Structure and Qualification Criteria

Product Hierarchy

Sales and COGS at the lowest level of detail available

This is referred to as transactional data

Variances and Schedule M’s can be apportioned

T x T benefits are driven by variability in profitability

Financial statements

Pro-forma income tax returns

Allocation and Apportionment of Deductions (“A&A”)

A&A Can enhance existing variability

T x T, Marginal Costing, Special No-loss rule all work together to

significantly boost DISC income!

53 53

Case Study Data

Client Provided Information

Account Description Total Non-Export Export

Sales 20,000,000 14,000,000 6,000,000

Returns & Allowances 0

Net Sales 20,000,000

Cost of Sales (11,000,000)

Gross Profit 9,000,000

Computed Inclusions and Gross Up:

Total Income 9,000,000

Interest (500,000)

R&D Expense (700,000)

Other Deductions (5,000,000)

Total Deduction (6,200,000)

Taxable Income before ETI and DPAD 2,800,000

Production Assets 1,000,000

54 54

Basic Calculation

A&A Account Type Summary Report by Export Subject: 1000 IC-DISC

Scenario: Simple IC-DISC Case

Tax Year: 2015

Purpose: U.S. Tax

Date and Time: 1/17/17 18:54


Sales 20,000,000 14,000,000 6,000,000

Returns & Allowances 0 0 0

Net Sales 20,000,000 14,000,000 6,000,000

Cost of Sales (11,000,000) (7,700,000) (3,300,000)

Gross Profit 9,000,000 6,300,000 2,700,000


Total Income 9,000,000 6,300,000 2,700,000

Interest (500,000) (350,000) (150,000)

R&D Expense (700,000) (490,000) (210,000)

Other Deductions (5,000,000) (3,500,000) (1,500,000)

Total Deduction (6,200,000) (4,340,000) (1,860,000)

Taxable Income before ETI and DPAD 2,800,000 1,960,000 840,000

Export Incentive Deduction - System (420,000) 0 (420,000)

Domestic Production Deduction - System 0 0 0

Taxable Income after ETI and DPAD 2,380,000 1,960,000 420,000

Income Taxes 0 0 0

Withholding Taxes 0 0 0

Net Income 2,380,000 1,960,000 420,000

55 55

Case Study – Transaction File

56 56 56

56

Case Study – Product Tree

58 58

Optimization Summary

A&A Account Type Summary Report by Export Subject: 1000 IC-DISC

Scenario: Simple DISC Opimization

Tax Year: 2015

Purpose: U.S. Tax

Date and Time: 1/17/17 19:02


Sales 20,000,000 14,000,000 6,000,000

Returns & Allowances 0 0 0

Net Sales 20,000,000 14,000,000 6,000,000

Cost of Sales (11,000,000) (7,700,000) (3,300,000) Gross Profit 9,000,000 6,300,000 2,700,000


Total Income 9,000,000 6,300,000 2,700,000

Interest (500,000) (350,000) (150,000) R&D Expense (700,000) (490,000) (210,000)

Other Deductions (5,000,000) (3,500,000) (1,500,000)

Total Deduction (6,200,000) (4,340,000) (1,860,000)

Taxable Income before ETI and DPAD 2,800,000 1,960,000 840,000

Export Incentive Deduction - System (784,552) 0 (784,552)

Domestic Production Deduction - System 0 0 0

Taxable Income after ETI and DPAD 2,015,448 1,960,000 55,448

Income Taxes 0 0 0

Withholding Taxes 0 0 0

Net Income 2,015,448 1,960,000 55,448

59 59

Summary of Pricing Methods

Sum By Batch Report Subject: 1000 IC-DISC

Scenario: Simple DISC Opimization

Tax Year: 2015

Purpose: U.S. Tax

Date and Time: 1/17/17 19:05

Pricing Batch Sales Gross Profit CTI Benefit

1 - FC-CTI 3,519,807 2,356,124 1,264,984 632,492

2 - MC-OPP limit 1,674,115 511,254 (7,721) 117,188

4 - MC-CTI 179,683 19,633 (36,070) 9,817

13 - Special No-Loss 626,395 (187,011) (381,193) 25,056

Total 6,000,000 2,700,000 840,000 784,552

Optimization Benefit:

Gross Receipts Method 6,000,000 2,700,000 840,000 240,000

Full Cost CTI Method 840,000 420,000

Best Method without Optimization 420,000

Increase in Benefit from Optimization 364,552

60 60

IRS Form 1120-IC-DISC

Schedule K vs. 1099

Schedule B - Gross Receipts

Number of Schedule P’s to support the income

Schedule E – IC-DISC Expenses

– Export Promotion Expenses

10% of Qualified Amount can increase IC-DISC Income

– Entitled to reimbursement of all expenses incurred by the IC-DISC

Schedule J – Complexity

– Deemed Dividends

– Accumulated DISC Income

Schedule L – Balance Sheet

Schedule O – Check Boxes Be Careful

Schedule Q – Producer’s Loans

61 61

Optimization Levers

Allocation and Apportionment

– Other than the prescribed methods for specific deductions, such as interest

and R&D, any method that is reasonable should be accepted.

– For example, sales, gross receipts, gross income, gross profit, cost of

goods sold, time spent, square footage, etc.

Pricing methods

– 4% gross receipts limited by either the regular or special no-loss rule

– 50% full cost or marginal cost limited by marginal cost combined taxable

income or the overall profit percentage limitation (OPP x QER)

Grouping alternatives

– Grouping for pricing and grouping for OPP

OPP Grouping

– May be broader than the pricing level (transaction or group)


Structuring the IC-DISC

Subsidiary of a Flow-Through

62

IC-DISC

US



Brother-Sister of a Flow-Through

63

IC-DISC

US



Brother-Sister of a C Corporation

64

IC-DISC

US

C Corp

The Interest Charge in IC-DISC

U.S. tax – with acc IC-DISC Inc.: $8.5 million

U.S. tax – without acc IC-DISC Inc.: $5 million

Deferred U.S. tax: $3.5 million

AFR: 1%

Interest: $350,000

U.S.

F

US

IC-

DISC

export customers

acc IC-DISC Inc.:

$10 million

Manufacturer

65


Structuring the IC-DISC Ownership by a Trust

US1 USN

U.S.

Foreign

. . . . . .

IC-DISC

Trust

C Corp

Exports

commission

dividends

beneficiaries

66


Structuring the IC-DISC Ownership by an LLC

U.S.

Foreign

US1

LLC

IC-DISC

Exports

commission

USN

C Corp

dividends

. . . . .

members

C Corp IC-DISC

US1 USN

LLC

67


Multiple C Corporations

US

F

US1

US5

. . . .

C Corp

IC-

DISC

C

Blocker

1

C

Blocker

2

C

Blocker

3

export customers

C Corp

68


Joint Venture: S Corp and Public Co

US

IC-

DISC

S

Corp

US

F

US1 USN . . . .

Public

Co

LLC

export

customers

commission

dividend

69


Gift Tax Implications?

US

F

US

S

Corp

IC-

DISC

commission

export

customers

dividend

Kid

70


Non-Family Members

US

F

US

S

Corp

IC-

DISC

export

customers

CMO

dividend

71


Trust For a Co-Op's Members

US

F

US1

IC-DISC

USN

dividend

. . . . . distributions

Co-Op

Trust

Export

customers

commission

72


Architects and Engineers

US

F

IC-

DISC

designs for

foreign projects

US

dividend

engineers

architects

73


Pure Distributor

US

F

IC-

DISC

export customers

US

dividend

unrelated

manufacturer

widgets

74


Inbound Treaty Benefits

IC-DISC USSub

75


Use of a Trust With Varying

Ownership Percentages

export customers

US

F

IC-DISC

F S D

S

export customers

90%

5% 5%

33%

33%

33%

Trust

LLC

76


Subpart F Income Created

US

HKCo

S US

F

PRC Customers

product

77


Avoid Subpart F Income With a

Related Foreign Export Corporation

S

widgets

$400

US

IC-

DISC commission

RFEC

other country export

customers

HKCo

same country

foreign customers

widgets

$500

US

F

78



Implementation Considerations

for the IC-DISC • Incorporate the IC-DISC before the export

sales begin

• Analyze the export sales

• Draft the commission agreement

• Prepare and timely file the Form 4876-A that

elects IC-DISC status

• Prepare a manual that contains guidelines

and a checklist/calendar 79


About Robert Misey

80

Robert Misey is Chair of the International

Department for Reinhart Boerner Van Deuren

and a member of the bar in California,

Wisconsin, and the District of Columbia.

A graduate of the law schools at Vanderbilt

University and Georgetown University, he is a former trial

attorney for the Internal Revenue Service Chief Counsel

(International) in Washington, DC. He is also the author of the

books A Practical Guide to U.S. Taxation of International

Transactions and Federal Taxation: Practice and Procedure.

Robert can be reached at either 312-207-5456

or 414-298-8135 or [email protected]

35409728

81 81

Questions and Contact Information

For additional questions on topics related to this discussion, please

contact:

Mark Gasbarra, CPA

National Managing Director

Forte International Tax, LLC

[email protected]

(847) 733-0645

www.forteintax.com

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