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a reference ID number or for

to enter both the EIN and the

An explanation of any basis or

permission to use these numbers.

reference ID number, but must enter

other adjustments made pursuant to

at least the EIN on line 4a.

section 367(a)(5) and any regulations

Note. In general, the reference ID

thereunder.

You must correlate the reference ID

number assigned to a transferee

numbers as follows: New reference ID

Line 2. If a partnership (whether

foreign corporation on Form 926 has

number [space] Old reference ID

foreign or domestic) transfers property

relevance only to Form 926 and

number. If there is more than one old

to a foreign corporation in an

should not be used with respect to the

reference ID number, you must enter

exchange described in section 367(a)

DRAFT AS OF

transferee foreign corporation on

a space between each such number.

(1), then a U.S. person that is a

other IRS forms.

As indicated above, the length of a

partner in the partnership shall be

Requirements. The reference ID

given reference ID number is limited

treated as having transferred a

number must be alphanumeric

to 50 characters and each number

proportionate share of the property in

(defined below) and no special

must be alphanumeric and no special

an exchange described in section

January 28, 2015

characters or spaces are permitted.

characters are permitted.

367(a)(1). A U.S. person's

The length of a given reference ID

proportionate share of partnership

Note. This correlation requirement

number is limited to 50 characters.

property shall be determined under

applies only to the first year the new

the rules and principles of sections

For these purposes, the term

reference ID number is used.

701 through 761 and the regulations

“alphanumeric” means the entry can

thereunder. See Temporary

be alphabetical, numeric, or any

Line 5. Address. Enter the

Regulations section 1.367(a)-1T(c)

combination of the two.

information in the following order: city,

(3).

province or state, and country. Follow

The same reference ID number

the country's practice for entering the

must be used consistently from tax

Line 2d. For definition of “regularly

postal code, if any. Do not abbreviate

year to tax year with respect to a given

traded on an established securities

the country name; however, if you file

transferee foreign corporation. If for

market,” see Temporary Regulations

electronically, please follow the

any reason a reference ID number

section 1.367(a)-1T(c)(3)(ii)(D). If the

convention specified.

falls out of use (for example, the

answer to line 2d is “Yes,” the rules of

transferee foreign corporation no

Regulations section 1.367(a)-1T(c)(3)

Line 6. Enter the two-letter country

longer exists due to disposition or

(ii)(C) apply.

code (from the list at

liquidation), the reference ID number

countrycodes) of the transferee

Part II—Transferee

used for that transferee foreign

foreign corporation's country of

corporation cannot be used again for

Foreign Corporation

incorporation or organization.

another transferee foreign corporation

Information

Line 7. List the entity classification

for purposes of Form 926 reporting.

(for example, partnership,

Reference ID number. A reference

There are some situations that

corporation, etc.) of the transferee

ID number is required on line 4b only

warrant correlation of a new reference

foreign corporation under the laws of

in cases where no EIN was entered

ID number with a previous reference

the country of incorporation or

on line 4a for the transferee foreign

ID number when assigning a new

organization.

corporation. However, filers are

reference ID number to a transferee

Line 8. See section 957(a) to

permitted to enter both an EIN and a

foreign corporation. For example:

determine whether the corporation is

reference ID number. If applicable,

In the case of a merger or

a controlled foreign corporation

enter on line 4b the reference ID

acquisition, a Form 926 filer must use

immediately after the transfer.

number (defined below) you have

a reference ID number which

assigned to the transferee foreign

correlates the previous reference ID

Part III—Information

corporation.

number with the new reference ID

Regarding Transfer of

number assigned to the transferee

A “reference ID number” is a

Property

foreign corporation.

number established by or on behalf of

In the case of an entity

the U.S. transferor identified at the top

Column (a). Date of transfer. Enter

classification election that is made on

of page 1 of the form that is assigned

the first date on which title to,

behalf of a transferee foreign

to the transferee foreign corporation

possession of, or rights to the use of

corporation on Form 8832,

with respect to which Form 926

the property passed for U.S. income

Regulations section 301.6109-1(b)(2)

reporting is required. These numbers

tax purposes. See Temporary

(v) requires the transferee foreign

are used to uniquely identify the

Regulations section 1.6038B-1T(b)(4)

corporation to have an EIN for this

transferee foreign corporation in order

for additional information.

election. For the first year that Form

to keep track of the entity from tax

926 is filed after an entity

year to tax year. The reference ID

Column (b). Description of proper-

classification election is made on

number must meet the requirements

ty. Provide a description of the

behalf of the transferee foreign

set forth below.

property transferred. With respect to

corporation on Form 8832, the new

section 6038B(a)(1)(A) transfers, see

Note. Because reference ID numbers

EIN must be entered on line 4a and

Temporary Regulations section

are established by or on behalf of the

the old reference ID number must be

1.6038B-1T(c)(4) for specific

U.S. person filing Form 926, there is

entered on line 4b. In subsequent

information that must be reported in

no need to apply to the IRS to request

years, the Form 926 filer may continue

column (b) (or, if necessary, under the

Instructions for Form 926 (Rev. 01-2015)

-3-

Instructions For Form 926 Draft - Return By A U.s. Transferor Of Property To A Foreign Corporation Page 4

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