Form 926 Compliance: Domestic Corporate Transfers to Foreign Subsidiaries and Related Corporations
Navigating IRC 6038 Corporate Rules for Transactions Involving Reorganization, Liquidation or Contribution Transfers
Recording of a 110-minute CPE webinar with Q&A
This course will provide corporate tax professionals with a comprehensive guide to complying with reporting obligations for contributions of cash or other property to foreign corporations. The panel will identify the types of transactions that trigger reporting obligations, discuss filing thresholds and information required to be reported on Form 926. The webinar will also cover the relationship and cross-referencing between Form 926 and other required foreign information filings, and detail the penalty regime for failure to report contributions to foreign corporations.
Outline
- Transactions requiring Form 926 reporting
- What must be reported on Form 926
- Special issues related to partnerships and hedge funds
- Penalties for noncompliance
Benefits
The panel will discuss these and other important issues:
- 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?
Faculty
Alison N. Dougherty, J.D., LL.M.
Director
Aronson
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and... | Read More
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She specializes in international tax compliance, planning and structuring as a subject matter leader of her firm's international tax practice. Her responsibilities include U.S. Federal and multi-state tax compliance for C corporations, S corporations, partnerships and individuals. She also provides transactional tax planning and structuring services.
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John Garcia, CPA
Owner
Corporate Tax Advisors
Mr. Garcia specializes in providing accounting, tax, and training services for mid-sized corporations with an... | Read More
Mr. Garcia specializes in providing accounting, tax, and training services for mid-sized corporations with an international footprint. Prior to starting his firm, he served as the head of tax for various large global consumer products companies for over a decade. In these roles he was responsible for all income tax planning, financial reporting, compliance and audits. He has a wealth of experience including settling multiple full scope international IRS audits and appeals, competent authority proceedings, and various international restructurings of organizations.
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