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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Friday, January 12, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This course will provide tax advisers and compliance professionals with a comprehensive guide to reporting transfers of property to foreign corporations, as well as review the technical analysis of the types of transactions that require such reporting. The panel will identify the types of transactions that trigger Form 926 reporting obligations and discuss required information to be reported on Form 926. The webinar will also cover the relationship between Form 926 and other required foreign information filings and address penalties for failure to report relevant transactions on Form 926.

Faculty

Kevin J. Brogan
Principal, International Tax, Washington National Tax
KPMG US, LLP

Mr. Brogan provides advice on a wide range of international tax issues, for both multinational and private equity clients, including foreign tax credits, earnings-stripping limitations, tax-efficient repatriations, and deficit planning. Throughout his career, he has worked on numerous cross-border mergers, acquisitions, dispositions, and internal restructurings.

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Daren J. Gottlieb
International Tax Senior Manager, Washington National Tax
KPMG US, LLP

Mr. Gottlieb specializes in domestic and cross-border transactions involving complex international tax issues. He has provided international tax advice for a  broad range of U.S. multi-national and foreign-owned clients doing business in the United States and foreign jurisdictions. Mr. Gottlieb received his JD from Western State College of Law and his LL.M. in Taxation from the Chapman University School of Law.

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Description

Section 6038B requires U.S. persons to report specific information to the IRS regarding property transfers to foreign persons in certain non-recognition transactions. While the Code and regulatory guidance are intended to prevent taxpayers from shifting appreciated property to foreign jurisdictions to avoid U.S. taxation, the reporting requirements apply whether or not the transferred asset has appreciated.

Taxpayers making these transfers must file Form 926 and include the form with their individual income tax return in the year of the transfer. The filing requirements apply for all property, including cash and intangible property, subject to certain requirements, ownership and valuation thresholds, and exceptions.

The information required on Form 926 can be extensive, and the penalties for noncompliance--10 percent of the fair market value of the property transferred, up to $100,000 and potential gain recognition as if the transfer were a sale for fair market value--are considerable. Moreover, technical expertise is necessary to identify when given transactions require such reporting. Further, the IRS uses Form 926 to verify consistency with other foreign reporting requirements, so a failure to file a complete and accurate Form 926 can result in additional tax consequences--such as FATCA penalties and extension of the statute of limitations.

Listen as our experienced panel provides a thorough and practical guide to completing Form 926 and complying with the relevant information reporting obligations.

Outline

  1. Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation
  2. Transactions requiring Form 926 reporting
  3. What must be reported on Form 926
  4. Unique issues related to partnerships and hedge funds
  5. Penalties for noncompliance
  6. Best practices

Benefits

The panel will discuss these and other relevant issues:

  • What types of transactions potentially require Form 926 reporting and what are the thresholds for Form 926 reporting?
  • A detailed walk-through of Form 926
  • What are the Form 926 reporting requirements when a partnership transfers property to a foreign corporation?
  • What are the challenges of completing Part III, Information Regarding Transfer of Property, and how Part III intersects with Form 5471 and FinCEN Form 114?
  • What are the calculations required to complete Part IV, Additional Information Regarding Transfer of Property?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Analyze whether a given transaction may require a Form 926 filing obligation
  • Decide when filing thresholds for both value and control are met requiring a Form 926 filing obligation
  • Identify critical calculations that must be reported in Part IV of Form 926
  • Determine the interrelation between amounts reported on Form 926 and other foreign information reporting requirements
  • Ascertain whether certain property transfers require reporting on Form 926

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, supervising other attorneys or accountants. Specific knowledge and understanding of foreign asset and contribution information reporting requirements; familiarity with IRS standards for foreign tax reporting, familiarity with FATCA and related reporting penalties.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).