Instructions For Form 926 Draft - Return By A U.s. Transferor Of Property To A Foreign Corporation Page 5

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Supplemental Information Required
rise to the reporting obligation (for
on Form 8832, Entity Classification
To Be Reported section or on
example, section 332, 351, 354, 356,
Election, or a termination of a section
attached sheets). With respect to
or 361).
1504(d) election), check the “Yes”
section 367(d) transfers, see
box. If the transfer was an actual
Line 11a. If gain recognition was
Temporary Regulations section
transfer of property to a foreign
required with respect to any transfer
1.6038B-1T(d). With respect to
corporation, check the “No” box.
reported in Part III under section
section 367(e) transfers, see
904(f)(3), attach a statement
Line 13. See final and temporary
Regulations section 1.6038B-1(e).
identifying the transfer and the
Regulations sections 1.367(a)-4
DRAFT AS OF
Column (c). Fair market value.
amount of gain recognized.
through 1.367(a)-6 for instances in
Enter the fair market value of the
which a transferor must recognize
Line 11b. If gain recognition was
property transferred (measured as of
income on the transfer of tangible
required with respect to any transfer
the date of transfer).
property that qualifies for
reported in Part III under section
nonrecognition treatment (see section
Column (d). Cost or other basis.
904(f)(5)(F), attach a statement
January 28, 2015
367(a)(3) and Temporary Regulations
Enter your adjusted basis in the
identifying the transfer and the
section 1.367(a)-2T). Additional
property transferred on the date of the
amount of gain recognized.
information is required to be attached
transfer. See sections 1011 through
Line 11c. If recapture was required
to this form. See Temporary
1016 for more information for the
with respect to any transfer reported
Regulations sections 1.6038B-1T(c)
determination of adjusted basis.
in Part III under section 1503(d) (dual
(4)(iii) and (vii), and 1.6038B-1T(c)(5).
Supplemental Information
consolidated loss), attach a statement
Line 17a. If you checked the "Yes"
identifying the transfer and the
Required To Be Reported
box, additional information is required
amount of recapture. See section
Enter any information from Part III that
to be attached to this form. See
1503(d) and the regulations
is required to be reported in greater
Temporary Regulations section
thereunder.
detail. Identify the applicable column
1.6038B-1T(d).
Line 11d. If exchange gain
number next to the information
Line 17b. See Temporary
recognition was required with respect
entered in this section. In addition, if
Regulations section 1.6038B-1T(d).
to any transfer reported in Part III
you contributed property to a foreign
under section 987, attach a statement
corporation as a part of a wider
identifying the transfer and the
transaction, briefly describe the entire
amount of exchange gain recognized.
transaction.
See Regulations section 1.987-5.
Part IV— Additional
Line 12. If this transfer resulted from
Information Regarding
a change in the classification of the
Transfer of Property
transferee to that of a foreign
corporation (a deemed transfer
Line 10. List the type of
resulting from a classification change
nonrecognition transaction that gave
Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the
United States. You are required to give us the information. We need it to ensure that you are complying with these laws
and to allow us to figure and collect the right amount of tax.
You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act
unless the form displays a valid OMB control number. Books or records relating to a form or its instructions must be
retained as long as their contents may become material in the administration of any Internal Revenue law. Generally, tax
returns and return information are confidential, as required by section 6103.
The time needed to complete and file this form will vary depending on individual circumstances. The estimated burden
for individual taxpayers filing this form is approved under OMB control number 1545-0074 and is included in the
estimates shown in the instructions for their individual income tax return. The estimated burden for all other taxpayers
who file this form is shown below.
Recordkeeping ........................................................................................23 hr., 26 min.
Learning about the law or the form ...........................................................6 hr., 58 min.
Preparing and sending the form to the IRS ..............................................14 hr., 51 min.
If you have comments concerning the accuracy of these time estimates or suggestions for making this form simpler,
we would be happy to hear from you. See the instructions for the tax return with which this form is filed.
-4-
Instructions for Form 926 (Rev. 01-2015)

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