EXPORT EXCEPTIONS AND EXEMPTIONS UNDER THE INTERNAL REVENUE CODE (IRC)
EXPORT ASSIST HAS USED THE EXPORT EXCEPTIONS AND EXEMPTIONS UNDER THE IRC TO CREATE NEW EXPORT TAX BENEFIT PROGRAMS FOR U.S EXPORTERS WITH A FOREIGN PRESENCE.
At this time, private and public exporters
with a foreign presence have several major concerns: how to bring
trapped Section 956 funds back into the U.S. without Subpart F exposure,
how to use their foreign tax credits accumulating offshore, and how
to lower their international effective tax rate.
In response to this, Export Assist researched
the export exceptions and exemptions under the IRC and had several
major law and accounting firms review its findings. The result was
the creation of a dedicated controlled foreign corporation (CFC)
that earns revenue by performing export activities and/or services.
The CFC enables you to use trapped offshore funds in the U.S. for
export financing thereby generating working capital that can reduce
investor and/or institutional borrowing. It also enables you to use
foreign tax credit carryforwards by treating dividends as foreign
source income and to lower your international effective tax rate
by accumulating deferred tax for an indeterminate period of time.
Export Assist has located its CFC in the U.S.
Virgin Islands. In
addition to the above benefits, the U.S.
Virgin Islands Export Corporation (VIEXCO) gives exporters the unique opportunity to
stay within the jurisdiction of the United States, including its
Federal Court, banking laws and mirrored tax code.