Document

Agency Information Collection Activities; Comment Request on Certain Transfers of Domestic Stock or Securities by U.S. Persons to Foreign Corporations

In accordance with the Paperwork Reduction Act of 1995, the IRS is inviting comments on the information collection request outlined in this notice.

Department of the Treasury
Internal Revenue Service

AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Notice of information collection; request for comments.

SUMMARY:

In accordance with the Paperwork Reduction Act of 1995, the IRS is inviting comments on the information collection request outlined in this notice.

DATES:

Written comments should be received on or before December 28, 2026 to be assured of consideration.

ADDRESSES:

Direct all written comments to Andres Garcia, Internal Revenue Service, Room 6526, 1111 Constitution Avenue NW, Washington, DC 20224, or by email to . Include “OMB Control No. 1545-1478” in the subject line of the message.

FOR FURTHER INFORMATION CONTACT:

Requests for additional information or copies of this collection should be directed to Kerry Dennis, (202) 317-5751.

SUPPLEMENTARY INFORMATION:

The IRS, in accordance with the Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3506(c)(2)(A)), provides the general public and Federal agencies with an opportunity to comment on proposed, revised, and continuing collections of information. This helps the IRS assess the impact and minimize the burden of its information collection requirements. Comments submitted in response to this notice will be summarized and/or included in the request for OMB approval. All comments will become a matter of public record, and viewable on relevant websites. For this reason, please do not include in your comments information of a confidential nature, such as sensitive personal information. Comments are invited on: (a) Whether the collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility; (b) the accuracy of the agency's estimate of the burden of the collection of information; (c) ways to enhance the quality, utility, and clarity of the information to be collected; (d) ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology; and (e) estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information.

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

OMB Control Number: 1545-1478.

Regulation Number: T.D. 8702.

Abstract: This regulation relates to certain transfers of stock or securities of domestic corporations to foreign corporations pursuant to the corporate organization, reorganization, or liquidation provisions of the Internal Revenue Code. Under section 367(a), these transfers generally result in the recognition of gain unless an applicable exception is satisfied. To qualify for the exception provided under 26 CFR 1.367(a)-3(c), the U.S. target company must comply with applicable reporting requirements and certain other conditions. The information collected is used by the IRS to determine whether the requirements for the exception have been satisfied.

Current Actions: There is no change to the previously approved information collection.

Type of Review: Extension of a currently approved collection.

Affected Public: Business or other for-profit organizations.

Estimated Number of Respondents: 100.

Estimated Time per Response: 10 minutes.

Estimated Total Annual Burden Hours: 1,000.

Dated: October 21, 2026.

Kerry Dennis,

Tax Analyst.

[FR Doc. 2026-21921 Filed 10-27-26; 8:45 am]

BILLING CODE 4831-GV-P

Legal Citation

Federal Register Citation

Use this for formal legal and research references to the published document.

91 FR 67910

Web Citation

Suggested Web Citation

Use this when citing the archival web version of the document.

“Agency Information Collection Activities; Comment Request on Certain Transfers of Domestic Stock or Securities by U.S. Persons to Foreign Corporations,” thefederalregister.org (October 28, 2026), https://thefederalregister.org/documents/2026-21921/agency-information-collection-activities-comment-request-on-certain-transfers-of-domestic-stock-or-securities-by-u-s-per.