IRS Seeks Comments on Stock Transfers to Foreign Corporations
Published Date: 10/28/2026
Notice
Summary
The IRS wants your thoughts on how it collects info when U.S. folks transfer stocks or securities to foreign companies. If you’re involved in these transfers, this could affect you by possibly changing paperwork rules or how much time you spend on them. Get your comments in by December 28, 2026, so the IRS can keep things clear and fair without extra hassle or costs.
Analyzed Economic Effects
2 provisions identified: 0 benefits, 1 costs, 1 mixed.
Reporting Needed to Claim 367(a) Exception
If a U.S. person transfers stock or securities of a domestic corporation to a foreign corporation, section 367(a) says those transfers usually cause recognition of gain unless an exception applies. To qualify for the exception under 26 CFR 1.367(a)-3(c), the U.S. target company must comply with applicable reporting requirements and provide information the IRS will use to determine whether the exception is satisfied.
Estimated Paperwork Burden for Respondents
The IRS estimates 100 respondents for this information collection, with an average of 10 minutes per response and a total annual burden of 1,000 hours. The notice states there is no change to the previously approved collection.
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