Stricter Reporting Requirements for U.S. Transferors of Property to Foreign Corporations

Excerpt from Practical US/International Tax Strategies by Andy Sikora and Joel Mitchell (BDO Seidman, LLP)


The Internal Revenue Service has issued revised Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation, to report exchanges of property with or transfers of property to a foreign corporation. The updated form requires greater detail regarding the property transferred and the tax consequences associated with the transfer. Form 926 is required for any United States person, corporation, estate, or trust that has exchanged property with, or transferred property to, a foreign corporation during the transferor’s taxable year in a transaction described in section 6038B(a), 367(d), or 367(e). Among others, affected transfers include transfers of cash (special rules may apply), stock, accounts receivable, intangible property, inventory, and depreciable assets. Revised Form 926 was released by the Service in February 2009 and contains a revision date of December 2008.

Read More on Form 926 Revisions >