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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 a No Yes Controlling shareholder c corporation. Name of parent corporation d Have basis adjustments under section 367 a 5 been made. EIN of parent corporation. complete questions 2a through 2d. 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 o ...

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What is a 926?

U.S. citizens or residents, domestic corporations or domestic estates or trusts must file Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation, to report any exchanges or transfers of tangible or intangible property (as described in section 6038B(a)(1)(A) of the Internal Revenue Code) to a foreign ...

What is a 351 contribution?

Section 351(a) provides that no gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control (as defined in § 368(c)) of the corporation.

What is the purpose of Form 5471?

U.S. citizens and residents who are officers, directors or shareholders in certain foreign corporations must file Form 5471 as part of their expat tax return. This form is officially called the Information Return of U.S. Persons with Respect to Certain Foreign Corporations.

What is a CFC for US tax purposes?

In the U.S., a CFC is a foreign corporation in which U.S. shareholders own more than 50% of the total combined voting power of all voting stock or the total value of the company's stock.

How do you qualify for 351?

See Multiple Transferors in a Section 351 Transfer. Control means ownership of at least 80 percent of all classes of the corporation's stock and at least 80 percent of the total voting power of all classes of stock. See Meeting the 80-Percent Control Test for Section 351 Transfers.

form 926 instructions 2022

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Can Form 5471 be filed?

Form 5471 should be filed as an attachment to the taxpayer's federal income tax, partnership or exempt organization return, and filed by the due date (including extensions) for that return. Failing to timely and accurately file Form 5471 may result in penalties and a reduction to foreign tax credit.

What is a CFC for US tax purposes?

In the U.S., a CFC is a foreign corporation in which U.S. shareholders own more than 50% of the total combined voting power of all voting stock or the total value of the company's stock.

What is a CFC for US tax purposes?

In the U.S., a CFC is a foreign corporation in which U.S. shareholders own more than 50% of the total combined voting power of all voting stock or the total value of the company's stock.

What is a CFC for US tax purposes?

In the U.S., a CFC is a foreign corporation in which U.S. shareholders own more than 50% of the total combined voting power of all voting stock or the total value of the company's stock.

Does 351 apply to cash contributions?

A contribution generally qualifies as a tax-free transaction under IRC Section 351 if: Cash or other property, or both, is transferred solely in exchange for stock in the corporation. The contributing parties are in control of the corporation immediately after a contribution.

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