Join international tax expert Alison Dougherty on September 7th for comprehensive Strafford webinar “Form 926 Compliance: Domestic Corporate Transfers to Foreign Subsidiaries and Related Corporations.” Alison will provide a complete guide to reporting contributions to foreign corporations and discuss filing thresholds and information required to be reported on Form 926. The panel will also discuss the relationship and cross-referencing between Form 926 and other required foreign information filings.
Section 6038 requires U.S. persons to make an information report to the IRS when making certain transfers of property to non-U.S. corporations in certain “non-recognition” transactions, as specified in Section 367. Taxpayers making these transfers must file Form 926 and include the form with their individual income tax return. Those not compliant with Form 926 could face penalties up to 10% of the market value of the asset transferred.
Commonly asked questions that will be addressed by the expert panel include:
- What are the thresholds for Form 926 reporting?
- What are the Form 926 reporting requirements when a U.S. domestic corporation transfers property to a controlled or related foreign corporation?
- What are the special rules applicable to corporations under the terms of Section 367?
- What is a “gain recognition agreement” and how does it impact reporting requirements?
- What are the challenges of completing Part III, Information Regarding Transfer of Property, and how does Part III intersect with Form 5471 and FinCEN Form 114?
- What are the calculations required to complete Part IV, Additional Information Regarding Transfer of Property?
After completing this course, you will be able to:
- Recognize the thresholds for both value and control in determining whether a taxpayer must file Form 926.
- Discern the exceptions to filing requirements and gain/loss recognition on transfers to foreign corporations.
- Identify critical calculations that must be reported in Part IV of Form 926.
- Demonstrate the interrelation between amounts reported on Form 926 and other foreign information reporting requirements such as FBAR/FinCEN Form 114.
- Determine information that must be included in Part III of Form 926.