Like Print

Information Document Request for Section 936 Exit Strategies

Pro-Forma IDR

Has the Taxpayer or any affiliate ever claimed a Possession Tax Credit pursuant to IRC Sec. 936?
If yes, please provide the following information:
- Copies of the Possession Corporation Forms 1120 for the years 1996 to date.
- Did the Possession Corporation ever transfer assets located in the possession territory to any other foreign affiliate? If yes provide:
  1. Detailed description of each asset transferred.
  2. Date of transfer for each asset.
  3. Value of each asset transferred.
  4. Identify the party to whom the asset(s) were transferred.
  5. Identify all assets transferred under any provision for which the transferor or transferee claimed the transfer was tax-free.
  6. Have any entities involved made an election under Treas. Reg. 1. 301.7701 (check-the-box)?
- Regarding the valuation of the assets transferred under item 2.b. above, please provide:
  1. Copies of all internal and external valuations and studies. This includes, but is not limited to, all valuations and studies obtained for US tax, financial accounting, and legal purposes and foreign tax, financial accounting, and legal purposes.
  2. Copies of all principal and background documentation outlined in Treas. Reg. Section 1.6662-6(d)(2)(iii)(B) & (C) that was prepared to support the valuation of the assets transferred.
- With regard to each intangible asset transferred, such as foreign goodwill & foreign going concern and workforce-in-place, please assure you have provided the information requested in items 2.b. and 2.c. above.

Page Last Reviewed or Updated: 2013-05-02