Form 926 PDF Details

The Form 926, revised in December 2011 by the Department of the Treasury Internal Revenue Service, plays a crucial role in the regulatory landscape for U.S. transferors of property to foreign corporations. This form is an attachment to the transferor's income tax return for the year in which the property transfer or distribution took place. It encompasses detailed sections including U.S. Transferor Information, Transferee Foreign Corporation Information, and expansive details regarding the transfer of property. The form seeks in-depth data such as the transferor's identifying number, specifics about the transfer including description, fair market value, and cost basis of the property transferred, and details on the foreign corporation receiving the property. Additionally, it requires disclosure of any gain recognized on the transfer, the transferor’s percentage interest in the foreign corporation before and after the transfer, and detailed information on the type of property transferred. Moreover, the form guides through identifying the type of nonrecognition transaction and indicates any gain recognition actions under various sections of the tax code. Its comprehensive nature ensures proper disclosure of transfers to foreign entities, aiming to monitor and tax such international transactions effectively.

QuestionAnswer
Form NameForm 926
Form Length3 pages
Fillable?No
Fillable fields0
Avg. time to fill out45 sec
Other namesTransferor, 2011, transferors, Transferee

Form Preview Example

Form 926

(Rev. December 2011)

Department of the Treasury

Internal Revenue Service

Return by a U.S. Transferor of Property

to a Foreign Corporation

▶Attach to your income tax return for the year of the transfer or distribution.

OMB No. 1545-0026

Attachment Sequence No. 128

Part I U.S. Transferor Information (see instructions)

Name of transferor

Identifying number (see instructions)

1If the transferor was a corporation, complete questions 1a through 1d.

aIf the transfer was a section 361(a) or (b) transfer, was the transferor controlled (under section 368(c)) by 5

or fewer domestic corporations? . . . . . . . . . . . . . . . . . . . . . . . . .

b Did the transferor remain in existence after the transfer? . . . . . . . . . . . . . . . . .

If not, list the controlling shareholder(s) and their identifying number(s):

Yes Yes

No No

Controlling shareholder

Identifying number

cIf the transferor was a member of an affiliated group filing a consolidated return, was it the parent corporation? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

If not, list the name and employer identification number (EIN) of the parent corporation:

Yes

No

Name of parent corporation

EIN of parent corporation

d Have basis adjustments under section 367(a)(5) been made? . . . . . . . . . . . . . . . .

Yes

No

2If the transferor was a partner in a partnership that was the actual transferor (but is not treated as such under section 367), complete questions 2a through 2d.

aList the name and EIN of the transferor’s partnership:

Name of partnership

EIN of partnership

b Did the partner pick up its pro rata share of gain on the transfer of partnership assets? . . . . . . .

c Is the partner disposing of its entire interest in the partnership? . . . . . . . . . . . . . . .

dIs the partner disposing of an interest in a limited partnership that is regularly traded on an established securities market? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Yes Yes

Yes

No No

No

Part II Transferee Foreign Corporation Information (see instructions)

3Name of transferee (foreign corporation)

4 Identifying number, if any

5Address (including country)

6Country code of country of incorporation or organization (see instructions)

7Foreign law characterization (see instructions)

8 Is the transferee foreign corporation a controlled foreign corporation? . . . . . . . . . . . . .

Yes

No

For Paperwork Reduction Act Notice, see separate instructions.

Cat. No. 16982D

Form 926 (Rev. 12-2011)

Form 926 (Rev. 12-2011)

 

 

 

Page 2

 

 

 

 

 

 

 

 

 

Information Regarding Transfer of Property (see instructions)

 

 

Part III

 

 

 

 

 

 

 

 

 

 

 

Type of

 

(a)

(b)

(c)

(d)

(e)

 

Date of

Description of

Fair market value on

Cost or other

Gain recognized on

property

 

 

transfer

property

date of transfer

basis

transfer

 

 

 

 

 

 

 

 

 

 

Cash

 

 

 

 

 

 

Stock and

 

 

 

 

 

 

 

 

 

 

 

 

securities

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Installment

 

 

 

 

 

 

 

 

 

 

 

 

obligations,

 

 

 

 

 

 

account

 

 

 

 

 

 

receivables or

 

 

 

 

 

 

 

 

 

 

 

 

similar property

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Foreign currency

 

 

 

 

 

 

 

 

 

 

or other property

 

 

 

 

 

denominated in

 

 

 

 

 

foreign currency

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Inventory

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Assets subject to

 

 

 

 

 

depreciation

 

 

 

 

 

 

 

 

 

 

 

 

recapture (see

 

 

 

 

 

 

 

 

 

 

Temp. Regs. sec.

 

 

 

 

 

1.367(a)-4T(b))

 

 

 

 

 

 

 

 

 

 

 

Tangible property

 

 

 

 

 

used in trade or

 

 

 

 

 

 

 

 

 

 

business not listed

 

 

 

 

 

 

 

 

 

 

under another

 

 

 

 

 

 

category

 

 

 

 

 

 

 

 

 

 

 

 

 

Intangible

 

 

 

 

 

 

 

 

 

 

 

 

property

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Property to be leased

 

 

 

 

 

 

 

 

 

 

(as described in final

 

 

 

 

 

and temp. Regs. sec.

 

 

 

 

 

1.367(a)-4(c))

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Property to be

 

 

 

 

 

sold (as

 

 

 

 

 

 

 

 

 

 

 

 

described in

 

 

 

 

 

 

 

 

 

 

 

 

Temp. Regs. sec.

 

 

 

 

 

1.367(a)-4T(d))

 

 

 

 

 

 

 

 

 

 

 

Transfers of oil and

 

 

 

 

 

gas working interests

 

 

 

 

 

 

 

 

 

 

(as described in

 

 

 

 

 

 

 

 

 

 

Temp. Regs. sec.

 

 

 

 

 

1.367(a)-4T(e))

 

 

 

 

 

 

 

 

 

 

 

 

Other property

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Supplemental Information Required To Be Reported (see instructions):

Form 926 (Rev. 12-2011)

Form 926 (Rev. 12-2011)

Page 3

 

 

 

Additional Information Regarding Transfer of Property (see instructions)

 

Part IV

 

9Enter the transferor’s interest in the foreign transferee corporation before and after the transfer:

(a) Before

 

% (b) After

%

 

 

 

 

 

10Type of nonrecognition transaction (see instructions) ▶

11Indicate whether any transfer reported in Part III is subject to any of the following:

a

Gain recognition under section 904(f)(3)

b

Gain recognition under section 904(f)(5)(F)

c

Recapture under section 1503(d)

d

Exchange gain under section 987

12Did this transfer result from a change in the classification of the transferee to that of a foreign corporation?

13Indicate whether the transferor was required to recognize income under final and temporary Regulations sections 1.367(a)-4 through 1.367(a)-6 for any of the following:

a

Tainted property

b

Depreciation recapture

c

Branch loss recapture

d

Any other income recognition provision contained in the above-referenced regulations

14Did the transferor transfer assets which qualify for the trade or business exception under section 367(a)(3)?

15a Did the transferor transfer foreign goodwill or going concern value as defined in Temporary Regulations section 1.367(a)-1T(d)(5)(iii)? . . . . . . . . . . . . . . . . . . . . . . . . . . .

bIf the answer to line 15a is “Yes,” enter the amount of foreign goodwill or going concern value

transferred ▶ $

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

No

No

No

No

No

No

No

No

16

Was cash the only property transferred?

17a

Was intangible property (within the meaning of section 936(h)(3)(B)) transferred as a result of the

 

transaction?

bIf “Yes,” describe the nature of the rights to the intangible property that was transferred as a result of the transaction:

Yes

Yes

No

No

Form 926 (Rev. 12-2011)

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This form will require you to type in specific information; in order to ensure accuracy and reliability, remember to adhere to the subsequent suggestions:

1. The OMB needs particular information to be entered. Be sure the next blank fields are filled out:

Tips to fill out 15a portion 1

2. When this array of fields is complete, it is time to include the needed particulars in Name of parent corporation, EIN of parent corporation, d Have basis adjustments under, Yes, If the transferor was a partner in, a List the name and EIN of the, Name of partnership, EIN of partnership, b Did the partner pick up its pro, Yes Yes, No No, Is the partner disposing of an, Transferee Foreign Corporation, Part II, and Yes so that you can go further.

15a completion process explained (step 2)

3. This subsequent segment is relatively simple, Foreign law characterization see, Is the transferee foreign, For Paperwork Reduction Act Notice, Cat No D, Yes, and Form Rev - all these empty fields is required to be completed here.

15a conclusion process detailed (stage 3)

It is easy to make errors when filling out the Is the transferee foreign, therefore be sure to go through it again before you finalize the form.

4. The following paragraph needs your information in the following places: Date of transfer, Description of, property, Fair market value on, date of transfer, Cost or other, basis, Gain recognized on, transfer, Type of property, Cash, Stock and securities, Installment obligations account, Foreign currency or other property, and Inventory. It is important to enter all of the needed details to go onward.

Part no. 4 of completing 15a

5. The document needs to be completed by filling in this section. Further you'll see a detailed listing of blanks that require correct details for your document submission to be faultless: Assets subject to depreciation, Intangible property, Property to be leased as described, Property to be sold as described, and Other property.

The best ways to complete 15a part 5

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