Return by a U.S. Transferor of Property                                            OMB No. 1545-0026
Form   926                                          to a Foreign Corporation
(Rev. November 2018)              ▶  Go to www.irs.gov/Form926 for instructions and the latest information.               Attachment   
Department of the Treasury      ▶ Attach to your income tax return for the year of the transfer or distribution.          Sequence No. 128
Internal Revenue Service 
Part I  U.S. Transferor Information (see instructions)
Name of transferor                                                                                   Identifying number (see instructions)

1      Is the transferee a specified 10%-owned foreign corporation that is not a controlled foreign corporation?  .          Yes          No
2      If the transferor was a corporation, complete questions 2a through 2d.
a      If the transfer was a section 361(a) or (b) transfer, was the transferor controlled (under section 368(c)) by
       five or fewer domestic corporations? .       . . . . .  . .   . .     .     . . . . . .       . .  .      . . .  .    Yes          No
b      Did the transferor remain in existence after the transfer?  . . .     .     . . . . . .       . .  .      . . .  .    Yes          No
       If not, list the controlling shareholder(s) and their identifying number(s).

                            Controlling shareholder                                          Identifying number

c      If the transferor was a member of an affiliated group filing a consolidated return, was it the parent 
       corporation? .       . . . . .  .   .  .     . . . . .  . .   . .     .     . . . . . .       . .  .      . . .  .    Yes          No
       If not, list the name and employer identification number (EIN) of the parent corporation.

                         Name of parent corporation                                      EIN of parent corporation

d      Have basis adjustments under section 367(a)(4) been made? .     .     .     . . . . . .       . .  .      . . .  .    Yes          No

3      If the transferor was a partner in a partnership that was the actual transferor (but is not treated as such under section 367), 
       complete questions 3a through 3d.
a      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 of gain on the transfer of partnership assets?  .    .  .      . . .  .    Yes          No
c      Is the partner disposing of its entire interest in the partnership? . .     . . . . . .       . .  .      . . .  .    Yes          No
d      Is the partner disposing of an interest in a limited partnership that is regularly traded on an established 
       securities market?  .    . . .  .   .  .     . . . . .  . .   . .     .     . . . . . .       . .  .      . . .  .    Yes          No
Part II Transferee Foreign Corporation Information (see instructions)
4      Name of transferee (foreign corporation)                                                        5a Identifying number, if any

6      Address (including country)                                                                     5b Reference ID number              
                                                                                                       (see instructions)

7      Country code of country of incorporation or organization (see instructions)

8      Foreign law characterization (see instructions)

9      Is the transferee foreign corporation a controlled foreign corporation? .     . . . . .       . .  .      . . .  .    Yes          No
For Paperwork Reduction Act Notice, see separate instructions.                       Cat. No. 16982D                    Form 926 (Rev. 11-2018)

Form 926 (Rev. 11-2018)                                                                                                                             Page 2 
Part III           Information Regarding Transfer of Property (see instructions)
Section A—Cash
          Type of             (a)                     (b)                        (c)                           (d)                       (e)  
          property       Date of                 Description of           Fair market value on            Cost or other           Gain recognized on 
                         transfer                   property                date of transfer                basis                      transfer
Cash

10         Was cash the only property transferred?. .      .  . .     . . .    . .    . .    . .   . .    .    .    .  . .    . .      Yes          No
           If “Yes,” skip the remainder of Part III and go to Part IV.

Section B—Other Property (other than intangible property subject to section 367(d))
          Type of             (a)                     (b)                        (c)                           (d)                       (e)  
          property       Date of                 Description of           Fair market value on            Cost or other           Gain recognized on 
                         transfer                   property                date of transfer                basis                      transfer
      Stock and 
     securities
Inventory          
        
         Other property  
(not listed under  
        another category)
      
     Property with  
built-in loss
     
Totals

11         Did the transferor transfer stock or securities subject to section 367(a) with respect to which a gain
           recognition agreement was filed? .  . .  .      .  . .     . . .    . .    . .    . .   . .    .    .    .  . .    . .      Yes          No
12 a       Were any assets of a foreign branch (including a branch that is a foreign disregarded entity) transferred to a 
           foreign corporation?   . . . .    . . .  .      .  . .     . . .    . .    . .    . .   . .    .    .    .  . .    . .      Yes          No
           If “Yes,” go to line 12b.
      b    Was the transferor a domestic corporation that transferred substantially all of the assets of a foreign branch 
           (including a branch that is a foreign disregarded entity) to a specified 10%-owned foreign corporation? .            .      Yes          No
           If “Yes,” continue to line 12c. If “No,” skip lines 12c and 12d, and go to line 13.
      c    Immediately after the transfer, was the domestic corporation a U.S. shareholder with respect to the
           transferee foreign corporation? . . . .  .      .  . .     . . .    . .    . .    . .   . .    .    .    .  . .    . .      Yes          No
           If “Yes,” continue to line 12d. If “No,” skip line 12d, and go to line 13.
      d    Enter the transferred loss amount included in gross income as required under section 91 ▶           $
13         Did the transferor transfer property described in section 367(d)(4)?  .    . .    . .   . .    .    .    .  . .    . .      Yes          No
           If “No,” skip Section C and questions 14a through 15.

Section C—Intangible Property Subject to Section 367(d)
                                                                                                                                       (f)  
          Type of        (a)                     (b)                      (c)                (d)                  (e)             Income inclusion 
          property       Date of               Description of             Useful      Arm’s length price  Cost or other basis   for year of transfer 
                         transfer              property                   life        on date of transfer                         (see instructions)
   
Property described 
in    sec. 367(d)(4)
    
Totals
                                                                                                                                Form 926 (Rev. 11-2018)

Form 926 (Rev. 11-2018)                                                                                                    Page 3 

14a Did the transferor transfer any intangible property that, at the time of the transfer, had a useful life
    reasonably anticipated to exceed 20 years?     .    . . . . .      . . . . . .        . . .  . .    . .     . .    Yes No
b   At the time of the transfer, did any of the transferred intangible property have an indefinite useful life? . .    Yes No
c   Did the transferor choose to apply the 20-year inclusion period provided under Regulations section
    1.367(d)-1(c)(3)(ii) for any intangible property? . . . . . .      . . . . . .        . . .  . .    . .     . .    Yes No
d   If the answer to line 14c is “Yes,” enter the total estimated anticipated income or cost reduction attributable 
    to the intangible property’s, or properties’, as applicable, use(s) beyond the 20-year period described in 
    Regulations section 1.367(d)-1(c)(3)(ii) ▶ $
15  Was any intangible property transferred considered or anticipated to be, at the time of the transfer or at any
    time thereafter, a platform contribution as defined in Regulations section 1.482-7(c)(1)?  . . .    . .     . .    Yes No

Supplemental Part III Information Required To Be Reported (see instructions)

Part IV Additional Information Regarding Transfer of Property (see instructions)

16  Enter the transferor’s interest in the transferee foreign corporation before and after the transfer.
    (a) Before          % (b) After                %
17  Type of nonrecognition transaction (see instructions) ▶
18  Indicate whether any transfer reported in Part III is subject to any of the following.
a   Gain recognition under section 904(f)(3) .   . .    . . . . .      . . . . . .        . . .  . .    . .     . .    Yes No
b   Gain recognition under section 904(f)(5)(F)  . .    . . . . .      . . . . . .        . . .  . .    . .     . .    Yes No
c   Recapture under section 1503(d)  .   .     . . .    . . . . .      . . . . . .        . . .  . .    . .     . .    Yes No
d   Exchange gain under section 987 .    .     . . .    . . . . .      . . . . . .        . . .  . .    . .     . .    Yes No
19  Did this transfer result from a change in entity classification? . . . . . . .        . . .  . .    . .     . .    Yes No
20a Did a domestic corporation make a distribution of property covered by section 367(e)(2)? See instructions .        Yes No
    If “Yes,” complete lines 20b and 20c.
b   Enter the total amount of gain or loss recognized pursuant to Regulations section 1.367(e)-2(b) ▶ $
c   Did the domestic corporation not recognize gain or loss on the distribution of property because the
    property was used in the conduct of U.S. trade or business under Regulations section 1.367(e)-2(b)(2)? .      .    Yes No
21  Did a domestic corporation make a section 355 distribution of stock in a foreign controlled corporation
    covered by section 367(e)(1)? See instructions      . . . . .      . . . . . .        . . .  . .    . .     . .    Yes No
                                                                                                                  Form 926 (Rev. 11-2018)