Instructions For Form 926 (Page 3 of 4) in pdf

Regulations section 1.367(a)-1T(c)(3)(ii)

corporation for purposes of Form 926

Line 8. See section 957(a) to

reporting.

determine whether the corporation is a

There are some situations that

controlled foreign corporation

Part II—Transferee

warrant correlation of a new reference

immediately after the transfer.

Foreign Corporation

ID number with a previous reference ID

Part III—Information

Information

number when assigning a new

reference ID number to a transferee

Regarding Transfer of

Reference ID number. A reference ID

foreign corporation. For example:

Property

number is required on line 4b only in

In the case of a merger or acquisition,

cases where no EIN was entered on

a Form 926 filer must use a reference ID

Column (a). Date of transfer. Enter

line 4a for the transferee foreign

number which correlates the previous

the first date on which title to,

corporation. However, filers are

reference ID number with the new

possession of, or rights to the use of the

permitted to enter both an EIN and a

reference ID number assigned to the

property passed for U.S. income tax

reference ID number. If applicable, enter

transferee foreign corporation.

purposes. See Temporary Regulations

on line 4b the reference ID number

In the case of an entity classification

section 1.6038B-1T(b)(4) for additional

(defined below) you have assigned to

election that is made on behalf of a

information.

the transferee foreign corporation.

transferee foreign corporation on Form

Column (b). Description of property.

8832, Regulations section

A “reference ID number” is a number

Provide a description of the property

301.6109-1(b)(2)(v) requires the

established by or on behalf of the U.S.

transferred. With respect to section

transferee foreign corporation to have

transferor identified at the top of page 1

6038B(a)(1)(A) transfers, see

an EIN for this election. For the first year

of the form that is assigned to the

Temporary Regulations section

that Form 926 is filed after an entity

transferee foreign corporation with

1.6038B-1T(c)(4) for specific

classification election is made on behalf

respect to which Form 926 reporting is

information that must be reported in

of the transferee foreign corporation on

required. These numbers are used to

column (b) (or, if necessary, under the

Form 8832, the new EIN must be

uniquely identify the transferee foreign

Supplemental Information Required To

entered on line 4a and the old reference

corporation in order to keep track of the

Be Reported section or on attached

ID number must be entered on line 4b.

entity from tax year to tax year. The

sheets). With respect to section 367(d)

In subsequent years, the Form 926 filer

reference ID number must meet the

transfers, see Temporary Regulations

may continue to enter both the EIN and

requirements set forth below.

section 1.6038B-1T(d). With respect to

the reference ID number, but must enter

section 367(e) transfers, see

Note. Because reference ID numbers

at least the EIN on line 4a.

Regulations section 1.6038B-1(e).

are established by or on behalf of the

You must correlate the reference ID

U.S. person filing Form 926, there is no

Column (c). Fair market value. Enter

numbers as follows: New reference ID

need to apply to the IRS to request a

the fair market value of the property

number [space] Old reference ID

reference ID number or for permission

transferred (measured as of the date of

number. If there is more than one old

to use these numbers.

transfer).

reference ID number, you must enter a

space between each such number. As

Column (d). Cost or other basis.

Note. In general, the reference ID

indicated above, the length of a given

Enter your adjusted basis in the

number assigned to a transferee foreign

reference ID number is limited to 50

property transferred on the date of the

corporation on Form 926 has relevance

characters and each number must be

transfer. See sections 1011 through

only to Form 926 and should not be

alphanumeric and no special characters

1016 for more information for the

used with respect to the transferee

are permitted.

determination of adjusted basis.

foreign corporation on other IRS forms.

Supplemental Information

Note. This correlation requirement

Requirements. The reference ID

applies only to the first year the new

Required To Be Reported

number must be alphanumeric (defined

reference ID number is used.

below) and no special characters or

Enter any information from Part III that is

spaces are permitted. The length of a

Line 5. Address. Enter the information

required to be reported in greater detail.

given reference ID number is limited to

in the following order: city, province or

Identify the applicable column number

50 characters.

state, and country. Follow the country's

next to the information entered in this

For these purposes, the term

practice for entering the postal code, if

section. In addition, if you contributed

“alphanumeric” means the entry can be

any. Do not abbreviate the country

property to a foreign corporation as a

alphabetical, numeric, or any

name; however, if you file electronically,

part of a wider transaction, briefly

combination of the two.

please follow the convention specified.

describe the entire transaction.

The same reference ID number must

Line 6. Enter the two-letter country

Part IV— Additional

be used consistently from tax year to tax

code (from the list at

Information Regarding

year with respect to a given transferee

countrycodes) of the transferee foreign

foreign corporation. If for any reason a

Transfer of Property

corporation's country of incorporation or

reference ID number falls out of use (for

organization.

example, the transferee foreign

Line 10. List the type of nonrecognition

Line 7. List the entity classification (for

corporation no longer exists due to

transaction that gave rise to the

example, partnership, corporation, etc.)

disposition or liquidation), the reference

reporting obligation (for example,

of the transferee foreign corporation

ID number used for that transferee

section 332, 351, 354, 356, or 361).

under the laws of the country of

foreign corporation cannot be used

Line 11a. If gain recognition was

incorporation or organization.

again for another transferee foreign

required with respect to any transfer

reported in Part III under section 904(f)

Instructions for Form 926 (Rev. 01-2015)

-3-

Instructions For Form 926 Page 3

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