Return by a U.S. Transferor of Property                                                OMB No. 1545-0026
Form   926                                          to a Foreign Corporation
(Rev. December 2017)              ▶  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      If the transferor was a corporation, complete questions 1a through 1d.
a      If the transfer was a section 361(a) or (b) transfer, was the transferor controlled (under section 368(c)) by 5
       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)(5) been made?  .    .      .    . . . . . .       . .  .      . . .  .     Yes          No

2      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 2a through 2d.
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)
3      Name of transferee (foreign corporation)                                                        4a Identifying number, if any

5      Address (including country)                                                                     4b Reference ID number              
                                                                                                       (see instructions)

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

7      Foreign law characterization (see instructions)

8      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. 12-2017)

Form 926 (Rev. 12-2017)                                                                                                                        Page 2 
Part III              Information Regarding Transfer of Property (see instructions)
Section A—Cash, Stock, and Securities
             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
Stock        and 
securities       (other 
than     those that 
qualify as eligible 
property         under 
Regs.        sec.  
    1.367(a)-2(b)(3))

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

10           Did the transferor transfer stock or securities subject to section 367(a) with respect to which a gain 
             recognition agreement was filed? . . .    . .  .     .     . . .    . .    . .    .  . . . .    .       . . . . .      Yes        No

Section B—Property qualifying for Active Trade or Business exception under Regs. sec. 1.367(a)-2(a)(2)(i) and (ii) 
             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*
Tangible         property 
(not     listed under 
another          category)
        
Working interest in 
oil     and gas property 
(as         described in 
Regs.        sec. 
1.367(a)-2(b)(2)      
and (f))
       
      Financial asset (as 
      described in Regs. 
     sec. 1.367(a)- 
     2(b)(3))
Certain      tangible 
property         to be 
leased       (see Regs. 
sec.     1.367(a)-2(e))
Totals
* If property listed in this section is subject to depreciation recapture or branch loss recapture, see instructions.
                                                                                                                             Form 926 (Rev. 12-2017)

Form 926 (Rev. 12-2017)                                                                                                                             Page 3 
Section C—Property not qualifying for Active Trade or Business exception (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*
   Inventory
    
   Installment 
obligations,    etc. (as 
described    in Regs. 
sec.    1.367(a)- 
2(c)(2))
    
    Nonfunctional 
currency,    etc. (as 
described    in Regs. 
sec.    1.367(a)- 
2(c)(3))
    
Certain    leased 
tangible    property 
(as    described in 
Regs.    sec. 
1.367(a)-2(c)(4))
    
Certain    property 
to be retransferred 
(see    Regs. sec. 
    1.367(a)-2(g))
    
Property     described 
in     Regs. sec. 
      1.6038B-1(c)(4)(iv)
Property     described 
in     Regs. sec. 
      1.6038B-1(c)(4)(vii)
Totals
* If property listed in this section is subject to depreciation recapture or branch loss recapture, see instructions.
11         Did the transferor transfer assets that qualify for the trade or business exception under section 367(a)(3)?                Yes          No
12         Indicate whether the transferor was required to recognize income under final and Temporary Regulations
           sections 1.367(a)-2 through 1.367(a)-7 for any of the following.
       a   Transfer of property subject to section 367(a)(1) gain recognition . .    . .    .  .  . .    .    .      .    . . . .      Yes          No
       b   Depreciation recapture  . . . .       . .   .  .  .     . . . .    . .    . .    .  .  . .    .    .      .    . . . .      Yes          No
       c   Branch loss recapture (see instructions)  . .  .  .     . . . .    . .    . .    .  .  . .    .    .      .    . . . .      Yes          No
       d   If the answer to 12c is “Yes,” enter the amount of foreign branch loss recapture ▶     $
       e   Any other income recognition provision contained in the above-referenced regulations  .            .      .    . . . .      Yes          No
           If the answer to line 12a, 12b, 12c, or 12e is “Yes,” see instructions for information that must be included in
           the Supplemental Part III Information Required To Be Reported section below.
Section D—Intangible property under Regs. sec. 1.367(a)-1(d)(5) 
                                                                                                                                       (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. 936(h)(3)(B)
    
Property     subject 
to sec. 367(d) 
pursuant     to Regs. 
sec.    1.367(a)-1(b)(5)
     
Totals
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Form 926 (Rev. 12-2017)                                                                                                               Page 4 

13a Did  the  transferor  transfer  property  described  in  section  936(h)(3)(B)  (not  including  section  1221(a)(3) 
    property or a working interest in oil and gas property)?  . . .     . .  . . . .      . . .  . .                   . . . .    Yes No
b   If the answer to line 13a is “Yes,” enter the total amount included in income under section 367
    (d),  if  any,  for  the  transfer  of  all  such  property  on  the  income  tax  return  for  the  year  of  the 
    transfer ▶ $
14a Did the transferor apply section 367(d) to a transfer of any property pursuant to Regulations section 
    1.367(a)-1(b)(5)? . . . .  . .    .  . .    .  .     . . .  . .     . .  . . . .      . . .  . .                   . . . .    Yes No
b   If the answer to line 14a is “Yes,” enter the total amount included in income under section 367
    (d),  if  any,  for  the  transfer  of  all  such  property  on  the  income  tax  return  for  the  year  of  the 
    transfer ▶ $
c   If the answer to line 14a is “No,” did the transferor transfer any property for which it could have applied 
    section 367(d) pursuant to Regulations section 1.367(a)-1(b)(5) but did not? . .      . . .  . .                   . . . .    Yes No
d   If  the  answer  to  line  14c  is  “Yes,”  enter  the  total  amount  of  gain  recognized,  if  any,  under 
    section 367(a)(1) on the transfer of all such property on the income tax return for the year of the 
    transfer ▶ $
15a Did the transferor transfer any intangible property that, at the time of the transfer, had a useful life 
    reasonably anticipated to exceed twenty 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  15c  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) ▶ $
16  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)

17  Enter the transferor’s interest in the foreign transferee corporation before and after the transfer.
    (a) Before            % (b) After           %
18  Type of nonrecognition transaction (see instructions) ▶
19  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
20  Did this transfer result from a change in entity classification?  . . .  . . . .      . . .  . .                   . . . .    Yes No
21a Did a domestic corporation make a distribution of property covered by section 367(e)(2) (see instructions)?                   Yes No
    If “Yes,” complete lines 21b and 21c.
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

                                                                                                                             Form 926 (Rev. 12-2017)