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Transfers of Tangible and Intangible Property to a Foreign Corporation


An in-depth look at the dozens of complex requirements for the filing of IRS Form 926 by U.

S. persons, estates and trusts who engage in exchanges or transfers of property to a foreign corporation.
The IRS is vigilant about preventing taxpayers from hiding offshore assets and earnings. Furthermore, in recent years the IRS has become increasingly aggressive about enforcing cross-border corporate reorganizations, divisions, and liquidations. Failure to file, misfiling, or underreporting can have substantial consequences with no statute of limitations. This course includes practical applications you can apply to client situations and will add to your overall knowledge about international tax compliance as it applies to U.S. investors and businesses with overseas holdings, as well as U.S. owners and beneficiaries of foreign trusts. You will learn, step-by-step, how to address the detailed rules and requirements in filing Form 926 to ensure compliance is met.



Jack Brister

Jack Brister


  • Managing member and founder of International Wealth Tax Advisors
  • Over 30 years of experience in forensic accounting, international tax and tax law
  • Formed International Wealth Tax Advisors (IWTA) in 2015 after leading the international tax division at Deloitte and Touche
  • Specializes in wealth-retention strategies for international investors, multinational businesses, family offices, and U.S. taxpayers working and living abroad
  • Specializes in wealth-retention strategies for international investors, multinational businesses, family offices, and U.S. taxpayers working and living abroad
  • Renowned in both the legal and accounting community as a preeminent expert on foreign trusts and estate taxation
  • Sought-after industry trainer and webinar leader; international speaker for STEP and other organizations
  • Former forensic accountant for U.S. Internal Revenue Service‚Äôs Criminal Investigation Unit
  • Regular author/contributor on international tax and the U.S. tax system to JD Supra, the business-to-business daily - circulation >500,000
  • Member of STEP, NYSSCPA, and EACCNY; board member, Laura Pels International Foundation for Theater
  • Can be contacted at [email protected]

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