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TEST YOUR KNOWLEDGE ON DISC #1
by Robert Feinschreiber
Oppenheim, Appe11 Dixon & Co.

Circle the correct answer for each of the following questions:

1.   A DISC purchased export property and leased the property to an unrelated third party (overseas).  The transaction produced qualified gross receipts.
T F

2. The intercompany price in the above transaction must be determined pursuant to Section 482.
T F

3. A DISC purchased export property from an unrelated company and sold the property to another unrelated company in a transaction producing qualified export receipts. The DISC may use the 50:50 pricing rule for the earlier transaction providing a profit resulted.
T F

4. Export property was sold to a purchaser in the Panama Canal Zone. The transaction produces qualified export receipts.
T F

5. The intercompany price in the above transaction must be determined pursuant to Section 482.
T F

6. Where X and Yare affiliates of a DISC, X manufactures a component and sells it to Y, Y includes the component in a finished product and sells it to the DISC, X's profit can be based on either the 4% or 50:50 computation.
T F

7. A DISC's profit on related and subsidiary services performed by its parent can be based on the 4~o or 50:50 computation.
T F

8. Where a DISC buys export property from a related party and sells the export property to a related property in a trans11ctLon giving rise to qualified export receipts, the profit realized by the DISC in the latter transaction can be safely computed under the 4% rule (subject to the no-loss restrictions).
T F

9. In the above fact pattern, the earlier transaction is ineligible for the 50:50 pricing rule.
T F

10. Sale of EXIM paper by a DISC's parent to the DISC is eligible for the 50:50 pricing rule.
T F

(For correct answers, see next DISCussion Bulletin)


For a copy of the entire article please contact:
ExportDISC Management Company
pursuant to Section 993(a)(1)(H) and Section 993(b)(2)
Robert Feinschreiber & Margaret Kent

1121 Crandon Blvd. F301
Key Biscayne, FL 33149
Primary Phone: 305.361.5800
or 305.505.9200
Fax: 305.365.2276
multijur@aol.com
www.exportDISC.com
www.transferpricingconsortium.com
export disc, domestic international sales corporation, export