TABLE OF CONTENTS

Acknowledgements

Introduction

Chapter 1 WESTERN HEMISPHERE TRADE CORPORATION (WHTC).

Introduction
Benefits.
Qualification Requirements
Domestic Corporation.
Business Location.
Western Hemisphere Defined
Incidental Purchases
Geographic Source of Income
The Active Business Requirement
Gross Income
Background
Intercompany Pricing
Notifying the IRS
Other Aspects

Chapter 2 DISC --THE DOMESTIC INTERNATIONAL SALES CORPORATION

An Overview of DISC
The Reasons for DISC
Qualification Requirements
Ineligible Corporations
Operating Requirements.
Gross Receipts
Assets
Qualified Assets and Receipts
Commissions
Leasing
Destination Test
Export Property
Used Machinery
Business Assets
Accounts Receivable
Working Capital
Funds in Excess of Working Capital
Eximbank and FCIA Obligations
Producer's Loans
Related Foreign Export Corporations
Services
Related and Subsidiary Services
Engineering, Architectural, and Construction Services
Managerial Services
Deficiency Distributions
DISC Benefits
Pricing and Profits
Related Supplier Rule

Chapter 3 WHTC AND DISC COMPARED

Origin of Goods
Place of Manufacture
BusinessSitus
Title Passage and Destination
Gross Receipts andGross
Deficiency Distribution
Assets
Intercompany Pricing
Taxable Year
Deduction Versus Deferral
Formation Requirements
Minimum Size
Foreign Tax Credit
Losses by the Related Manufacturer
Conclusion

DISC BIBLIOGRAPHY

APPENDICES

WHTC Rulings

DISC Rulings

Legislative History of WHTC and DISC

WHTC and DISC Sections of the Internal Revenue Code.

Federal Income Tax Regulations for WHTC and DISC

INDEX