Free Form 926 (Rev. December 2008) - Federal

Form (Rev. December 2008)
Department of the Treasury Internal Revenue Service

926

Return by a U.S. Transferor of Property to a Foreign Corporation
Attach to your income tax return for the year of the transfer or distribution.

OMB No. 1545-0026 Attachment Sequence No.

128

Part I

U.S. Transferor Information (see instructions)
Identifying number (see instructions)

Name of transferor

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? b Did the transferor remain in existence after the transfer? If not, list the controlling shareholder(s) and their identifying number(s): Controlling shareholder Identifying number

Yes Yes

No No

c If the transferor was a member of an affiliated group filing a consolidated return, was it the parent corporation? If not, list the name and employer identification number (EIN) of the parent corporation: Name of parent corporation EIN of parent corporation

Yes

No

d Have basis adjustments under section 367(a)(5) been made? 2

Yes

No

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? c Is the partner disposing of its entire interest in the partnership? d Is the partner disposing of an interest in a limited partnership that is regularly traded on an established securities market?

Yes Yes Yes

No No No

Part II
3 5 6 7 8

Transferee Foreign Corporation Information (see instructions)
4 Identifying number, if any

Name of transferee (foreign corporation) Address (including country) Country code of country of incorporation or organization (see instructions) Foreign law characterization (see instructions) Is the transferee foreign corporation a controlled foreign corporation?

Yes
Cat. No. 16982D Form

No

For Paperwork Reduction Act Notice, see separate instructions.

926

(Rev. 12-2008)

Form 926 (Rev. 12-2008)

Page

2

Part III
Type of property

Information Regarding Transfer of Property (see instructions)
(a) Date of transfer (b) Description of property (c) Fair market value on date of transfer (d) Cost or other basis (e) Gain recognized on transfer

Cash Stock and securities

Installment obligations, account receivables or similar property Foreign currency or other property denominated in foreign currency

Inventory

Assets subject to depreciation recapture (see Temp. Regs. sec. 1.367(a)-4T(b)) Tangible property used in trade or business not listed under another category

Intangible property Property to be leased (as described in Temp. Regs. sec. 1.367(a)-4T(c)) Property to be sold (as described in Temp. Regs. sec. 1.367(a)-4T(d)) Transfers of oil and gas working interests (as described in Temp. Regs. sec. 1.367(a)-4T(e))

Other property

Supplemental Information Required To Be Reported (see instructions):

Form

926

(Rev. 12-2008)

Form 926 (Rev. 12-2008)

Page

3

Part IV

Additional Information Regarding Transfer of Property (see instructions)

9 Enter the transferor's interest in the foreign transferee corporation before and after the transfer: (a) Before 10 11 a b c d 12 13 a b c d 14 % (b) After %

Type of nonrecognition transaction (see instructions) Indicate whether any transfer reported in Part III is subject to any of the following: Gain recognition under section 904(f)(3) Gain recognition under section 904(f)(5)(F) Recapture under section 1503(d) Exchange gain under section 987 Did this transfer result from a change in the classification of the transferee to that of a foreign corporation? Indicate whether the transferor was required to recognize income under Temporary Regulations sections 1.367(a)-4T through 1.367(a)-6T for any of the following: Tainted property Depreciation recapture Branch loss recapture Any other income recognition provision contained in the above-referenced regulations Did the transferor transfer assets which qualify for the trade or business exception under section 367(a)(3)?

Yes Yes Yes Yes Yes

No No No No No

Yes Yes Yes Yes Yes

No No No No No

15a Did the transferor transfer foreign goodwill or going concern value as defined in Temporary Regulations section 1.367(a)-1T(d)(5)(iii)? b If the answer to line 15a is "Yes," enter the amount of foreign goodwill or going concern value transferred $ 16 Was cash the only property transferred?

Yes

No

Yes

No

17a Was intangible property (within the meaning of section 936(h)(3)(B)) transferred as a result of the transaction? b If "Yes," describe the nature of the rights to the intangible property that was transferred as a result of the transaction:

Yes

No

Form

926

(Rev. 12-2008)