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26 CFR Part 1
[REG-118926-97]
RIN 1545-AV70
public hearing.
regulations.
http://www.irs.ustreas.gov/prod/tax_regs/comments.html.
Washington, DC.
SUPPLEMENTARY INFORMATION:
technology; and
by 26 U.S.C. 6103.
Background
Taxpayer Relief Act of 1997
- 5 -
and 6046A does not expire until three years after the information
version of the form will be issued for public comment while the
exchange, unless the failure was due to reasonable cause and not
was imposed under section 6038B if the transfer was not reported.
transfer.
other than cash that occur on or after July 20, 1998, generally
future regulations.
trusts. The tax was equal to 35 percent of the fair market value
Explanation of Provisions
Reporting of Cash Transfers to Foreign Corporations
operations).
- 8 -
that in certain cases the necessary books and records are not
Information Required
then the transfer must be reported on the Form 8865 (and filed in
as if the property had been sold for its fair market value at the
Effective Dates
The amendments to the regulations on the reporting of cash
Special Analyses
It has been determined that this notice of proposed
fact that the amount of time required to complete the form and
hearing starts.
making comments.
hearing.
Drafting Information
The principal authors of these proposed regulations are
follows:
corporations.
* * * * *
this section and must attach the required information to Form 926
* * * * *
corporation if--
* * * * *
(5). * * *
* * * * *
partnerships.
return of income) for the taxable year that includes the date of
in the partnership; or
attached to, and filed by the due date (including extensions) of,
the transferor’s income tax return for the year in which the
disposition occurred.
for the period in which the transfer occurs, then the United
States person must report under this section on the Form 8865 for
transfer occurred (not its own taxable year) and file with its
(h).
metB-
foreign partnership;
be satisfied;
(ii) Identifying the person who has or will file the return;
created or organized;
transfer;
interest;
the property)--
(iii) Cash;
securities; and
events, includingB-
made.
section, then--
contributed property had been sold for fair market value at the
comply was due to reasonable cause and not willful neglect. The
return for the year of the transfer, setting forth the reasons
6501(c)(8).
in section 7701(a)(30).
income tax return for the first taxable year beginning after the
Register.
this section.
Michael P. Dolan