Department of Treasury November 19, 2014 – Federal Register Recent Federal Regulation Documents

Failure To File Gain Recognition Agreements or Satisfy Other Reporting Obligations
Document Number: 2014-27365
Type: Rule
Date: 2014-11-19
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final and temporary regulations relating to the consequences to U.S. and foreign persons for failing to file gain recognition agreements (GRAs) or related documents, or to satisfy other reporting obligations, associated with certain transfers of property to foreign corporations in nonrecognition exchanges. The regulations are necessary to update and clarify the rules that apply when a U.S. or foreign person fails to file a GRA or related documents or to satisfy other reporting obligations. These regulations affect U.S. and foreign persons that transfer property to foreign corporations in nonrecognition exchanges.