Form 926 (Rev. December 2017) F926

User Manual: 926

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Form 926
(Rev. December 2017)
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
Go to www.irs.gov/Form926 for instructions and the latest information.
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.
a
If the transfer was a section 361(a) or (b) transfer, was the transferor controlled (under section 368(c)) by 5
or fewer domestic corporations? . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
bDid the transferor remain in existence after the transfer? . . . . . . . . . . . . . . . . . Yes No
If not, list the controlling shareholder(s) and their identifying number(s).
Controlling shareholder Identifying number
c
If the transferor was a member of an affiliated group filing a consolidated return, was it the parent
corporation? ................................ Yes No
If not, list the name and employer identification number (EIN) of the parent corporation.
Name of parent corporation EIN of parent corporation
dHave basis adjustments under section 367(a)(5) been made? . . . . . . . . . . . . . . . . Yes No
2
If 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
bDid the partner pick up its pro rata share of gain on the transfer of partnership assets? . . . . . . . Yes No
cIs the partner disposing of its entire interest in the partnership? . . . . . . . . . . . . . . . Yes No
d
Is the partner disposing of an interest in a limited partnership that is regularly traded on an established
securities market? .............................. Yes No
Part II Transferee Foreign Corporation Information (see instructions)
3 Name of transferee (foreign corporation) 4a Identifying number, if any
4b Reference ID number
(see instructions)
5 Address (including country)
6 Country code of country of incorporation or organization (see instructions)
7 Foreign law characterization (see instructions)
8Is the transferee foreign corporation a controlled foreign corporation? . . . . . . . . . . . . . Yes No
For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 16982D Form 926 (Rev. 12-2017)
Form 926 (Rev. 12-2017) Page 2
Part III Information Regarding Transfer of Property (see instructions)
Section A—Cash, Stock, and Securities
Stock and
securities (other
than those that
qualify as eligible
property under
Regs. sec.
1.367(a)-2(b)(3))
Type of
property
(a)
Date of
transfer
(b)
Description of
property
(c)
Fair market value on
date of transfer
(d)
Cost or other
basis
(e)
Gain recognized on
transfer
Cash
9Was cash the only property transferred? . . . . . . . . . . . . . . . . . . . . . . . Yes No
If “Yes,” skip the remainder of Part III and go to Part IV.
10 Did the transferor transfer stock or securities subject to section 367(a) with respect to which a gain
recognition agreement was filed? . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
Section BProperty qualifying for Active Trade or Business exception under Regs. sec. 1.367(a)-2(a)(2)(i) and (ii)
Tangible property
(not listed under
another category)
Working interest in
oil and gas property
(as described in
Regs. sec.
1.367(a)-2(b)(2)
and (f))
Financial asset (as
described in Regs.
sec. 1.367(a)-
2(b)(3))
Certain tangible
property to be
leased (see Regs.
sec. 1.367(a)-2(e))
Type of
property
(a)
Date of
transfer
(b)
Description of
property
(c)
Fair market value on
date of transfer
(d)
Cost or other
basis
(e)
Gain recognized on
transfer*
Totals
* If property listed in this section is subject to depreciation recapture or branch loss recapture, see instructions.
Form 926 (Rev. 12-2017)
Form 926 (Rev. 12-2017) Page 3
Section CProperty not qualifying for Active Trade or Business exception (other than intangible property subject to section
367(d))
Inventory
Installment
obligations, etc. (as
described in Regs.
sec. 1.367(a)-
2(c)(2))
Nonfunctional
currency, etc. (as
described in Regs.
sec. 1.367(a)-
2(c)(3))
Certain leased
tangible property
(as described in
Regs. sec.
1.367(a)-2(c)(4))
Certain property
to be retransferred
(see Regs. sec.
1.367(a)-2(g))
Property described
in Regs. sec.
1.6038B-1(c)(4)(iv)
Property described
in Regs. sec.
1.6038B-1(c)(4)(vii)
Type of
property
(a)
Date of
transfer
(b)
Description of
property
(c)
Fair market value on
date of transfer
(d)
Cost or other
basis
(e)
Gain recognized on
transfer*
Totals
* If property listed in this section is subject to depreciation recapture or branch loss recapture, see instructions.
11 Did the transferor transfer assets that qualify for the trade or business exception under section 367(a)(3)? Yes No
12 Indicate whether the transferor was required to recognize income under final and Temporary Regulations
sections 1.367(a)-2 through 1.367(a)-7 for any of the following.
aTransfer of property subject to section 367(a)(1) gain recognition . . . . . . . . . . . . . . . Yes No
bDepreciation recapture ............................ Yes No
cBranch loss recapture (see instructions) . . . . . . . . . . . . . . . . . . . . . . . Yes No
dIf the answer to 12c is “Yes,” enter the amount of foreign branch loss recapture $
eAny other income recognition provision contained in the above-referenced regulations . . . . . . . Yes No
If the answer to line 12a, 12b, 12c, or 12e is “Yes,” see instructions for information that must be included in
the Supplemental Part III Information Required To Be Reported section below.
Property described
in sec. 936(h)(3)(B)
Property subject
to sec. 367(d)
pursuant to Regs.
sec. 1.367(a)-1(b)(5)
Section DIntangible property under Regs. sec. 1.367(a)-1(d)(5)
Type of
property
(a)
Date of
transfer
(b)
Description of
property
(c)
Useful
life
(d)
Arm's length price
on date of transfer
(e)
Cost or other basis
(f)
Income inclusion
for year of transfer
(see instructions)
Totals
Form 926 (Rev. 12-2017)
Page 4
Form 926 (Rev. 12-2017)
13a Did the transferor transfer property described in section 936(h)(3)(B) (not including section 1221(a)(3)
property or a working interest in oil and gas property)? . . . . . . . . . . . . . . . . . . Yes No
bIf the answer to line 13a is “Yes,” enter the total amount included in income under section 367
(d), if any, for the transfer of all such property on the income tax return for the year of the
transfer $
14a Did the transferor apply section 367(d) to a transfer of any property pursuant to Regulations section
1.367(a)-1(b)(5)?............................... Yes No
bIf the answer to line 14a is “Yes,” enter the total amount included in income under section 367
(d), if any, for the transfer of all such property on the income tax return for the year of the
transfer $
cIf the answer to line 14a is “No,” did the transferor transfer any property for which it could have applied
section 367(d) pursuant to Regulations section 1.367(a)-1(b)(5) but did not? . . . . . . . . . . . Yes No
dIf the answer to line 14c is “Yes,” enter the total amount of gain recognized, if any, under
section 367(a)(1) on the transfer of all such property on the income tax return for the year of the
transfer $
15a Did the transferor transfer any intangible property that, at the time of the transfer, had a useful life
reasonably anticipated to exceed twenty years? . . . . . . . . . . . . . . . . . . . . Yes No
bAt the time of the transfer, did any of the transferred intangible property have an indefinite useful life? . . Yes No
cDid the transferor choose to apply the 20-year inclusion period provided under Regulations section
1.367(d)-1(c)(3)(ii) for any intangible property? . . . . . . . . . . . . . . . . . . . . . Yes No
dIf the answer to line 15c is “Yes,” enter the total estimated anticipated income or cost
reduction attributable to the intangible property's, or properties', as applicable, use(s) beyond
the 20-year period described in Regulations section 1.367(d)-1(c)(3)(ii) $
16 Was any intangible property transferred considered or anticipated to be, at the time of the transfer or at any
time thereafter, a platform contribution as defined in Regulations section 1.482-7(c)(1)? . . . . . . . Yes No
Supplemental Part III Information Required To Be Reported (see instructions)
Part IV Additional Information Regarding Transfer of Property (see instructions)
17 Enter the transferor’s interest in the foreign transferee corporation before and after the transfer.
(a) Before %(b) After %
18 Type of nonrecognition transaction (see instructions)
19 Indicate whether any transfer reported in Part III is subject to any of the following.
aGain recognition under section 904(f)(3) . . . . . . . . . . . . . . . . . . . . . . . Yes No
bGain recognition under section 904(f)(5)(F) . . . . . . . . . . . . . . . . . . . . . . Yes No
cRecapture under section 1503(d) . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
dExchange gain under section 987 . . . . . . . . . . . . . . . . . . . . . . . . . Yes No
20 Did this transfer result from a change in entity classification? . . . . . . . . . . . . . . . . Yes No
21a Did a domestic corporation make a distribution of property covered by section 367(e)(2) (see instructions)? Yes No
If “Yes,” complete lines 21b and 21c.
bEnter the total amount of gain or loss recognized pursuant to Regulations section 1.367(e)-2(b) $
cDid the domestic corporation not recognize gain or loss on the distribution of property because the
property was used in the conduct of U.S. trade or business under Regulations section 1.367(e)-2(b)(2)? . . Yes No
Form 926 (Rev. 12-2017)

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