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#family-business

Family Business

Guidance for family-owned businesses on governance, succession, and managing family dynamics

The IC-DISC Export Tax Strategy: How Closely-Held U.S. Exporters Cut Their Tax Rate on Foreign Sales to 20 Percent

An IC-DISC is a paper-only U.S. C corporation authorized by IRC Sections 991–997 that lets closely-held manufacturers, distributors, and growers convert qualifying export profit from ordinary income rates (up to 37%) into qualified dividend rates (20–23.8%), with typical setups producing $50,000+ in annual federal tax savings on $5M of qualifying export sales after Section 199A's 2026 sunset widened the rate spread.

Section 754 Election: How Partnerships Use Inside Basis Step-Ups to Save Incoming Partners and Heirs From Phantom Gains

A Section 754 election lets a partnership adjust the inside basis of its assets when an interest transfers or property is distributed, preventing incoming partners and heirs from being taxed on appreciation that economically belonged to the seller. The election is permanent, covers both 743(b) and 734(b) adjustments, and matters most for real estate, family, and professional service partnerships.