ITS Outlook -- IRS Insights on FSC / ETI Effective Dates for Long-Term Contracts

David Joranko, a senior partner in EY's International Tax Services Group in Cleveland, addresses recent IRS Chief Counsel advice on the effective dates for claiming benefits under the foreign sales corporation (FSC) and extraterritorial income (ETI) rules on long-term sales and lease transactions. This is of particular interest to U.S. exporters with long-term sales and contracts, such as those in the defense industry, and those with long-term leases or licenses, such as those in the film, software, and financial services industries.