926
Return by a U.S. Transferor of Property
OMB No. 1545-0026
Form
to a Foreign Corporation
(Rev. December 2011)
Attachment
Department of the Treasury
128
Attach to your income tax return for the year of the transfer or distribution.
Sequence No.
▶
Internal Revenue Service
Part I
U.S. Transferor Information (see instructions)
Name of transferor
Identifying number (see instructions)
1
If 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? .
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Yes
No
b Did the transferor remain in existence after the transfer?
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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
Yes
No
corporation? .
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If not, list the name and employer identification number (EIN) of the parent corporation:
Name of parent corporation
EIN of parent corporation
d Have basis adjustments under section 367(a)(5) been made? .
Yes
No
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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.
a List 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?
Yes
No
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c Is the partner disposing of its entire interest in the partnership? .
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Yes
No
d Is the partner disposing of an interest in a limited partnership that is regularly traded on an established
securities market? .
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Yes
No
Part II
Transferee Foreign Corporation Information (see instructions)
3
Name of transferee (foreign corporation)
4 Identifying number, if any
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Address (including country)
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Country code of country of incorporation or organization (see instructions)
7
Foreign law characterization (see instructions)
8
Is the transferee foreign corporation a controlled foreign corporation? .
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Yes
No
926
For Paperwork Reduction Act Notice, see separate instructions.
Form
(Rev. 12-2011)
Cat. No. 16982D