A Miami-based manufacturer of high-pressure, high-temperature (HPHT) completion tools for the oil industry engaged McGuire Sponsel in optimizing its export incentives.

Exporters seeking to maintain competitiveness must consider IC-DISC structuring, especially as domestic tax incentives and rate regimes shift under the One Big Beautiful Bill.

In the post-OBBBA environment, foreign reporting obligations, cross-border audits, and compliance risk demand greater vigilance.

Cross-border business remains one of the most complex and high-stakes advisory areas. As the One Big Beautiful Bill Act introduces changes affecting corporate tax structures and international flows, transfer pricing is more strategic — and more scrutinized — than ever.

Host Jerry Hammel, CPA, is joined by Catherine Yuan, CPA, to discuss the essentials of international tax compliance for business leaders.

As the federal tax landscape continues to shift under the One Big Beautiful Bill Act and its ripple effects, CPAs face a critical moment: how to balance proactive planning with compliance while strengthening their advisory role.

The IRS and Treasury plan to roll back Disregarded Payment Loss (DPL) and Dual Consolidated Loss (DCL) rules after industry pushback. Learn how these proposed changes could ease compliance burdens, affect international tax planning, and what CPAs and advisors need to know before the October 21, 2025, comment deadline.

The G7 has backed a side-by-side framework that treats U.S. rules like GILTI and NCTI as equivalent under OECD Pillar Two, shielding U.S. companies from foreign top-up taxes. For CPAs, this development simplifies compliance and modeling while underscoring the need to monitor OECD implementation closely.

 

The One Big Beautiful Bill replaces the FDII deduction with a streamlined Foreign-Derived Deduction-Eligible Income (FDDEI) regime. While the changes simplify compliance and remove certain offsets, they also reduce the deduction rate and expand exclusions, prompting CPAs to revisit export-focused tax planning.

Host Tim LeMasters and guest Jason Rauhe, CPA, dive into the complexities of the new One Big, Beautiful Bill (OB3) and its shifts in US international tax law.

Logo
  • Oil Tool Manufacturer

    Miami, FL

  • Company Profile

    Manufacturer of high-pressure, high-temperature completion tools for the oil industry

  • Project Type

    IC-DISC

  • Project Objective

    Realize export incentives

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Approach & Results

Client Profile

A Miami-based manufacturer of high-pressure, high-temperature (HPHT) completion tools for the oil industry engaged McGuire Sponsel in optimizing their export incentives. With extensive experience designing tools capable of withstanding extreme reservoir conditions, the company specializes in creating innovative equipment for challenging international markets.

Process

Our Global Business team worked closely with the CPA and client to evaluate their qualification for an IC-DISC (Interest Charge Domestic International Sales Corporation) and provide comprehensive support for incorporation, calculations, and tax return preparation. The project involved multiple discussions analyzing the client’s financials, future projections, and tax-planning opportunities.

A critical challenge emerged due to the client’s late-year engagement. With IC-DISC commissions only applicable after incorporation, our team executed an expedited incorporation process to ensure the client could maximize their potential tax benefits.

Project Results

Through strategic IC-DISC implementation, our Global Business team helped the client realize a substantial tax benefit of $162,000. The swift incorporation and meticulous planning allowed the manufacturer to optimize their export-related tax incentives, demonstrating our ability to deliver significant financial value through specialized tax strategies.

Contact Us

If you or your client are moving goods, people, services, and information across borders we are here to guide you.

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Additional Resources

  • webinars
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    December 3, 2025

    IC-DISC & Export Incentives for 2026

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    Exporters seeking to maintain competitiveness must consider IC-DISC structuring, especially as domestic tax incentives and rate regimes shift under the...

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