Introducing DISC Grouping and Transaction-by-Transaction Methodology
The DISC grouping process and the transaction-by-transaction method frequently impact the allocation of profits between a DISC and its related supplier:
We examine combinations of transactions that can advantageous, and transactions that can be detrimental. This analysis presupposes that the reader is already familiar with DISC pricing. We specifically examine transactions having a profitability that is between 4 percent and 8 percent, based on combined taxable income divided by gross receipts, by examining two grouping patterns:
This article provides an introduction to grouping and transaction-by-transaction methodology, and specifically examines the benefits and detriments of applying grouping and transaction-by-transaction methodologies to two transaction categories:
DISC Grouping and Transaction-by-Transaction RegulationsThe taxpayer’s understanding of the DISC pricing methods is essential for the DISC qualification and for maximizing DISC benefits. This analysis describes transactional grouping requirements under section 1.994-1(c)(7), specifically examining empirical practical grouping strategies. Grouping, as we shall see, can have a major impact,
 Feinschreiber, R., and Kent, M., Understanding the DISC Pricing Methods, Corporate Business Taxation Monthly, June 2006, 23-36.
 Feinschreiber, Domestic International Sales Corporations, Practising Law Institute, 1978, Part III, 207-284: Feinschreiber, New Strategies for Increasing DISC Benefits, 44 Financial Executive 32, 1976.
 Napp Systems, Inc., 65 TCM 2567, Dec. 49,022(M), TC Memo 1993-196; Feinschreiber, Domestic International Sales Corporations, Practising Law Institute, 1978, Chapter 11, pp. 247-274; Feinschreiber, How to Aggregate DISC Sales to Make Use of the Deferral, 36 J. Tax 300, 1972.