In a recent decision, the United States Court of Appeals for the Sixth Circuit in Summa Holdings, Inc. v. Comm’r, 2017-1 U.S.T.C ¶50,155, (February 16, 2017) reversed the holding of the Tax Court, 109 TCM 1612 confirming the legitimacy of the strategy of using a Domestic International Sales Corporation (DISC) as a vehicle to fund […]