Page 299 - International Taxation IRS Training Guides
P. 299

Possible
                                                   Transactions (Cont’d)






             US Sub4


                   •	  Outbound transfer
                                                           of property
                   •	  USP
                                 files Form 926 for assets

                            US Sub4
                        of                                                           US Sub4
                             CFC4
                   •	  Likely
                                   files a Gain Recognition
                                             (GRA)
                        Agreement

                   •	  Files
                                 initial Form 5471


             CFC3


                   •	  Parent
                                     would file Form 926 for
                        its                                                            CFC3
                             stock owned by US Sub4

                   •	  GRA
                                  likely filed for CFC3
                        stock


                   •	  Continues
                                           to file its Form 5471



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