Certain Transfers of Domestic Stock or Securities by U.S. Persons to Foreign Corporations

Transfers of stock or securities by U.S. persons in tax-free transactions are treated as taxable transactions when the acquirer is a foreign corporation, unless an exception applies (section 367(a)). Under the regulations, no U.S. person will qualify for an exception unless the U.S. target company complies with certain reporting requirements.

The latest form for Certain Transfers of Domestic Stock or Securities by U.S. Persons to Foreign Corporations expires 2027-04-30 and can be found here.