AICPA/Export Assist, Inc. – Workshop on Export Tax Benefits

At this intensive 2-day workshop, export experts will teach you how to maximize your tax benefits.  Learn how to analyze and structure your company’s export activity in order to maximize tax benefits using an IC-DISC or the Export Exceptions and Exemptions under the Internal Revenue Code (IRC), especially Sections 954 and 956. 

WHO SHOULD ATTEND
Directors or Senior Managers, corporate tax and financial executives from law and accounting firms, CFOs, Tax Directors or Managers, Controllers and Treasurers and other financial executives involved with export tax benefits. No prerequisite is necessary.

June 10, 2010 – Day One
Interest Charge Domestic International Sales Corporation (IC-DISC)

7:30am Registration and Continental Breakfast

8:00am Welcome and Introduction
Joseph G. Englert, President, Export Assist, Inc., San Francisco, CA

8:15 am Overview of Export Tax Benefits and Exporter Profiles
David Wain, Partner, Worldwide Trade Partners LLC, Minneapolis, MN

• History of export tax benefits
• Export tax benefit legislation
• Exporter profile

9:00am IC-DISC – How It Works and Overview of Requirements
Neal J. Block, Partner, Baker & McKenzie, LLP, Chicago, IL

• IC-DISC structure
• Definition of export property
• Qualified export assets
• Categories of gross receipts
• Commission calculation and selection
• How the interest charge works
• Implementing the IC-DISC

10:00am Break for Refreshments

10:15am Combined Taxable Income, Expense Allocations and Export P&L
David Wain, Partner, Worldwide Trade Partners LLC, Minneapolis, MN

• Creating export profit and loss statement
• Developing IC-DISC activity accounting system
• Identifying qualified export receipts and assets
• Tracking costs of goods sold
• Expense allocation and apportionment of deductions
• Transfer pricing methods
• Full and marginal costing

11:15am Increasing IC-DISC Revenue
Joseph G. Englert, President, Export Assist, Inc., San Francisco, CA

• Exporter profile
• Export profit and loss statement
• Safe harbor commission IC-DISC
• Safe harbor buy/sell IC-DISC
• Buy/sell IC-DISC
• Export invoice factoring
• IC-DISC with Foreign International Sales Corporation (FISC)
• Dividend and deferral

12:15pm Luncheon

1:30pm IC-DISC Ownership Structures
Neal J. Block, Partner, Baker & McKenzie, LLP, Chicago, IL

• Privately-held company: C, S, LLC and partnership
• Publicly-traded corporation
• Individual Retirement Account (IRA) and Roth IRA
• Estate planning and executive compensation
• Treaty benefits
• Sourcing benefits

2:15pm IC-DISC Operations, Compliance and Asset Management
Joseph G. Englert, President, Export Assist, Inc., San Francisco, CA

• IC-DISC operations: implementation, annual management and accounting
• IC-DISC compliance
• Calculating the commissions
• Timing options for initial commission payment
• Timing for commission redetermination
• Asset management

3:00pm Break for Refreshments

3:15pm Compliance for IRS Form 1120 IC-DISC
David Wain, Partner, Worldwide Trade Partners LLC, Minneapolis, MN

• When to file
• Who must sign
• Examination of Form 1120 IC-DISC and schedules
• Examination of Form 8404 – interest charge on the deferred tax

4:00pm Case Study: Completion of Sample IRS Form 1120 IC-DISC
David Wain, Partner, Worldwide Trade Partners LLC, Minneapolis, MN

Receive comprehensive hands-on experience preparing IRS form and schedules for a commission IC-DISC.

5:00pm One-on-One “Ask the Experts”
David Wain, Partner, Worldwide Trade Partners LLC, Minneapolis, MN
Neal J. Block, Partner, Baker & McKenzie, LLP, Chicago, IL
Joseph G. Englert, President, Export Assist, Inc., San Francisco, CA

Private question and answer session with a faculty member about specific issues relating to you or your client’s IC-DISC.

5:30pm Day One Workshop Concludes

June 11, 2010 – Day Two
Export Exceptions and Exemptions under the IRC

7:30am Registration and Continental Breakfast

8:00am Introduction to Export Exceptions and Exemptions
Joseph G. Englert, President, Export Assist, Inc., San Francisco, CA

• Tax and Treasury Strategy
• Section 954 - Creating a related export corporation exempt from Sec. 954 (Subpart F)
• Section 956 - Release of funds trapped offshore
• Foreign tax credits (FTC)
• U.S. Virgin Islands Export Corporation (VIEXCO)

8:30 am Exporter Profiles
Scott Wentz, Managing Director, CPA, MBA, Montage Services, Inc., San Francisco, CA

• Exporting without a foreign presence
• Exporting with a foreign presence
• Local foreign tax consequences
• Exporting with the use of local entities
• Export tax incentives

9:15am Outbound Export Transactions, Offshore Funds Accumulation, Deferral and Foreign Tax Credits
Scott Wentz, Director, CPA, MBA, Montage Services, Inc., San Francisco, CA

• Exporting offshore deferral and foreign tax credits (FTC)
• Foreign base company sales income (unrelated U.S. purchase and unrelated export sale, same country exemptions, contract manufacturing)
• Foreign base company services income (services for export transactions)
• Foreign personal holding company income (export financing interest, active leasing and royalties)

10:15am Refreshment Break

10:30am Section 956 Inbound Export-Related Financing Exceptions Using Accumulated Funds
Scott Wentz, Director, CPA, MBA, Montage Services, Inc., San Francisco, CA

• Overview of Section 956
• U.S. property
• U.S. property calculation
• Export exception
• Gross income inclusion computations

11:15am Export-Related Property Eligible under Section 956
Joseph G. Englert, President, Export Assist, Inc., San Francisco, CA

• Export transaction financing and structure
• Export transaction financing for pre-export working capital
• Export accounts receivable (short-term)
• Export factoring
• Export notes receivable (medium-term)
• Export inventory
• Private Export Funding Corporation (PEFCO) notes for export asset compliance

12:15pm Luncheon

1:30pm Use of Foreign Tax Credits
Scott Wentz, Director, CPA, MBA, Montage Services, Inc., San Francisco, CA

• Foreign tax credit limitation
• Inventory sourcing and apportionment
• General foreign tax credit limitation
• Inventory planning
• Filing Form 1118 (corporate) and Form 1116 (individual) for FTC

2:15pm The Export Corporation Exception: U.S. Virgin Islands
Joseph G. Englert, President, Export Assist, Inc., San Francisco, CA

• Legislative origin of the Virgin Islands Export Corporation (VIEXCO)
• Positioning, ownership and structure
• Local income tax and filings
• IRC definition of qualified export property and receipts
• VIEXCO export activities
• VIEXCO tax benefits
• Filing of Form 5471 by U.S. shareholders

3:00pm Refreshment Break

3:15pm Management of Virgin Islands Export Corporation (VIEXCO)
Joseph G. Englert, President, Export Assist, Inc., San Francisco, CA

• Exception and exemption compliance monitoring
• Performing finance functions like a bank
• Accounting and issuance of statements
• Management of business process and test for substantial contribution

4:00pm One-on-One “Ask the Experts”
Joseph G. Englert, President, Export Assist, Inc., San Francisco, CA
Scott Wentz, Director, CPA, MBA, Montage Services, Inc., San Francisco, CA

An excellent opportunity to have a private question and answer session with a faculty member about export exceptions and exemptions and how they apply to your company or your client.

5:00pm Day Two Workshop Concludes

AICPA Offices
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Lewisville, TX  75057-6408

Hotel Information:
Homewood Suites Dallas/Lewisville
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Hotel Phone: 972.315.6123
Hotel Reservations: 800.420.9013
Hotel Room Rate: $129.00 single/double
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