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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.

97 minutes
Course Exam
Certificate of Completion
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Why Lorman?

Over 35 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

The Purpose of Form 926

  • Ensure Taxes on Transfers of Property by U.S. Persons to Foreign Corporations Are Paid
  • Prevents U.S. Persons From Avoiding Taxes
  • Basics of International Taxation

International Taxation Basics

  • Complexity of Form 926
  • Terms and Definitions
  • Basic Concepts

Changes From Temporary to Proposed Regulations

  • Eliminating Goodwill, Narrowing Definitions
  • Recognizing Income Under IRC 936 Regulations
  • No Favorable Treatment of Intangibles

Form 926 Section-By-Section

  • Purpose
  • Requirements
  • Exceptions

Form 926 Section-By-Section

  • Cash
  • Types of Property
  • Additional Requirements
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Why Lorman?

Over 35 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

This course was last revised on August 18, 2022.

Call 1-866-352-9540 for further credit information.

  • AIPB 1.5
     
  • This program is acceptable for 1.5 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     
  • Enrolled Agents 1.0
     
  • This program qualifies for 1.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
     

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 35 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Jack Brister

Jack Brister

Consultant

  • 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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Why Lorman?

Over 35 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Pay once and get a full year of unlimited training in any format, any time!

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  • State Specific Credit Tracker
  • All-Access Pass Course Concierge

Questions? Call 877-296-2169 to speak with a real person.

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Product ID: 409987
Published 2022
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