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Note. This correlation requirement

attached sheets). With respect to section

statement identifying the transfer and the

applies only to the first year the new

367(d) transfers, see Temporary

amount of gain recognized.

reference ID number is used.

Regulations section 1.6038B-1T(d). With

Line 11c. If recapture was required with

respect to section 367(e) transfers, see

Line 5. Address. Enter the information in

respect to any transfer reported in Part III

Regulations section 1.6038B-1(e).

the following order: city, province or state,

under section 1503(d) (dual consolidated

and country. Follow the country's practice

Column (c). Fair market value. Enter

loss), attach a statement identifying the

for entering the postal code, if any. Do not

the fair market value of the property

transfer and the amount of recapture. See

abbreviate the country name; however, if

transferred (measured as of the date of

section 1503(d) and the regulations

DRAFT AS OF

you file electronically, please follow the

transfer).

thereunder.

convention specified.

Column (d). Cost or other basis. Enter

Line 11d. If exchange gain recognition

Line 6. Enter the two-letter country code

your adjusted basis in the property

was required with respect to any transfer

(from the list at

transferred on the date of the transfer. See

reported in Part III under section 987,

countrycodes) of the transferee foreign

sections 1011 through 1016 for more

attach a statement identifying the transfer

corporation's country of incorporation or

information for the determination of

and the amount of exchange gain

May 21, 2013

organization.

adjusted basis.

recognized. See Regulations section

1.987-5.

Line 7. List the entity classification (e.g.,

Supplemental information required

partnership, corporation, etc.) of the

Line 12. If this transfer resulted from a

to be reported

transferee foreign corporation under the

change in the classification of the

laws of the country of incorporation or

transferee to that of a foreign corporation

Enter any information from Part III that is

organization.

(a deemed transfer resulting from a

required to be reported in greater detail.

classification change on Form 8832, Entity

Identify the applicable column number

Line 8. See section 957(a) to determine

Classification Election, or a termination of

next to the information entered in this

whether the corporation is a controlled

a section 1504(d) election), check the

section. In addition, if you contributed

foreign corporation immediately after the

“Yes” box. If the transfer was an actual

property to a foreign corporation as a part

transfer.

transfer of property to a foreign

of a wider transaction, briefly describe the

corporation, check the “No” box.

entire transaction.

Part III—Information

Line 13. See final and temporary

Regarding Transfer of

Part IV— Additional

Regulations sections 1.367(a)-4 through

Property

Information Regarding

1.367(a)-6 for instances in which a

transferor must recognize income on the

Transfer of Property

Column (a). Date of Transfer. Enter the

transfer of tangible property that qualifies

first date on which title to, possession of,

for nonrecognition treatment (see section

Line 10. List the type of nonrecognition

or rights to the use of the property passed

367(a)(3) and Temporary Regulations

transaction that gave rise to the reporting

for U.S. income tax purposes. See

section 1.367(a)-2T). Additional

obligation (e.g., section 332, 351, 354,

Temporary Regulations section

information is required to be attached to

356, or 361).

1.6038B-1T(b)(4) for additional

this form. See Temporary Regulations

information.

Line 11a. If gain recognition was required

sections 1.6038B-1T(c)(4)(iii) and (vii),

with respect to any transfer reported in

Column (b). Description of property.

and 1.6038B-1T(c)(5).

Part III under section 904(f)(3), attach a

Provide a description of the property

Line 17a. If you checked the "Yes" box,

statement identifying the transfer and the

transferred. With respect to section

additional information is required to be

amount of gain recognized.

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

attached to this form. See Temporary

Regulations section 1.6038B-1T(c)(4) for

Line 11b. If gain recognition was required

Regulations section 1.6038B-1T(d).

specific information that must be reported

with respect to any transfer reported in

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

Line 17b. See Temporary Regulations

Part III under section 904(f)(5)(F), attach a

Supplemental Information section or on

section 1.6038B-1T(d).

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., 12 min.

Learning about the law or the form ...........................................................6hr., 52min.

Preparing and sending the form to the IRS ..............................................14hr., 44 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.

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

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