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Bilzin Sumberg

Commission Payments to IC-DISC Recharacterized as Non-Deductible Dividends

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In Summa Holdings, Inc. v. Commissioner, T.C. Memo 2015-119, the Tax Court recharacterized an exporter’s deductible commission payments made to an IC-DISC as non-deductible dividend payments to the exporter’s shareholders...more

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