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Taxpayers already enjoying a higher profit margin on export sales than on worldwide sales of a product or product line hardly would seem to be those Congress had in mind when it granted the Commissioner regulatory authority in section 994(b)(2) to allow special rules for those "seeking to establish or maintain a market for export property." Id. The shareholders of a DISC, or a former DISC, are subject to taxation on the earnings and profits of the DISC by way of distributions from the DISC in accordance with the provisions of chapter 1 of the Code generally applicable to shareholders, but subject to the modifications provided in IRC §§ 995, 996, and 997. You should start by gaining an understanding of the R-S's and DISC's business.
We find such effect reasonable in that it excludes from marginal costing taxpayers who logically would not need special tax incentives to be encouraged to export -- i.e., those taxpayers whose export profit margin already is higher than their worldwide profit margin with respect to the product in question. Below is a summary of the sections and reporting requirements that apply.
Most of the expenses incurred to generate the QER are on the books of the R-S.
It is common to become confused when reviewing a DISC return for the first time. This background will enable you to focus your attention on the portions of the regulations that apply to your case, and which expenses should be allocated to the QER. This Audit Guide is broken out into five sections: Section I. - The DISC Law and Major Concepts, a Code and Regulation section approach to some of the major concepts of the DISC.  There are three divisions of earnings and profits of a DISC, or former DISC from which distributions to shareholders may be made : To audit the DISC, you must understand more than the concepts expressed above, regarding the applicable sections of the IRC. Questions that need to be asked include what is being sold and how, when, and where is it manufactured. - Introduction – Purpose, Format and Limitations Section II. You must know the audit trail from the books and records of the DISC and R-S to the tax returns of the DISC and R-S. Learn about the selling function and who purchased the products. Money fund investors should carefully consider information contained in the money fund prospectus, or, if available, the summary prospectus, including investment objectives, risks, charges, and expenses.You can request a mutual fund prospectus by calling Schwab at 1-800-435-4000.