Value-priced Form 926 — transfers to a foreign corporation

Form 926 — who files it, when it is due, what late filing costs, and what we charge to prepare it. United States (IRS). Value-priced Form 926 with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

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  • 15+ years of cross-border experience
  • Fixed fee agreed before work starts
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In 60 words

Form 926 is an information return: Reports a US person's transfer of property — cash, shares, intangibles — to a foreign corporation. US transferors who contribute property to a foreign corporation on formation or afterwards, above the reporting level.

Whether this is your situation

US transferors who contribute property to a foreign corporation on formation or afterwards, above the reporting level.

Start with the mechanism, not the form. Capitalising the foreign company you just set up is a reportable transfer. It is one of the quietest filings in the international set, and its penalty is computed as a percentage of the value transferred.

Two of the firm’s advisers and the team in the open-plan office

Fixed fees for form 926 transfer foreign corporation, agreed up front

The fee for a Form 926 turns on what was transferred and how much of it needs valuing. Cash into a newly formed foreign company is straightforward; shares, intangibles, or a series of contributions through the year each need their own description and basis figures. Every transfer is quoted in writing first.

T1134 foreign affiliate reporting — fixed-fee price

From $999

fixed, quoted before work starts

The foreign affiliate return with a full set of schedules per affiliate, restated onto the basis the return requires rather than the basis the local accounts use.
See the full fee page

T106 information return — fixed-fee price

From $999

fixed, quoted before work starts

The related-party transaction return, reconciled to the corporate return and to the non-resident slips so the three tell one consistent story.
See the full fee page

Foreign asset & information reporting

From $349

fixed, quoted before work starts

Foreign holdings mapped once — accounts, real property, shareholdings — then reported to each authority in the form it requires.
See the fee schedule

Corporate cross-border filing

From $999

fixed, quoted before work starts

Corporate compliance for a group that trades or holds assets in more than one country, prepared on both sides together.
See the fee schedule

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Local file, master file and benchmarking for groups trading across borders, documented to the standard the authority expects.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

Personal returns for individuals, expats and non-residents — foreign income, foreign property and treaty relief handled in one engagement.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

What an employer owes when an employee works in another country: the registrations, the withholding and the reporting that follow.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

Returns for the year you leave, the year you arrive, and the years you earn rental or pension income from a country you no longer live in.
See the fee schedule

All published fees on one page — the whole fee schedule in one place, with no from-to bands to decode.

What the reporting test actually looks at

What decides whether Form 926 applies
What the test looks atWhere the figure comes from
The obligationReports a US person's transfer of property — cash, shares, intangibles — to a foreign corporation.
Who it bindsUS transferors who contribute property to a foreign corporation on formation or afterwards, above the reporting level.
Jurisdiction and authorityUnited States — IRS
Category of filingInformation return

When it is due

Information returns are generally due with — or on the same timetable as — the return they accompany, so the deadline is the filing deadline of the underlying return unless the rules set a separate date. Where an extension covers the return, confirm whether it also covers this form; several information returns keep their own date. Where an extension is available we tell you what it does and does not cover, because the two are frequently confused.

What late or missed filing costs

The penalty on an information return is charged per form and per year, and it does not depend on tax being owed. That is the whole risk profile: a filer with no tax to pay can still accumulate a substantial liability across unfiled years, and the exposure compounds with each additional entity or account that should have been reported. If that exposure has already accumulated, it is a disclosure question rather than a filing question, and the assessment comes first.

The arithmetic, worked through

Put numbers against it and the shape of the answer is obvious.

Why three small accounts are reportable

Three ordinary foreign accounts, none of which looks like a reporting problem on its own. The account report is tested on the aggregate of all foreign financial accounts at their highest point in the calendar year.

Why three small accounts are reportable
ItemAmount
Current account, highest balanceUS$6,000
Savings account, highest balanceUS$3,000
Account held with a relative, signature authority onlyUS$3,000
Aggregate tested against the thresholdUS$12,000
Reporting threshold (verified, FinCEN)US$10,000

The aggregate of US$12,000 exceeds the US$10,000 threshold, so all three accounts are reported — including the one that is not the filer's money, because signature authority counts. Change any one of those inputs and the answer moves, which is why we run it on your own figures rather than on an illustration.

Illustrative figures, not a client engagement: the amounts are chosen to make the mechanism legible, and the rates and thresholds are assumptions stated for the example only. We confirm every one of them against the issuing authority for your own tax year before anything is filed.

How we prepare and file it, and what it costs

We quote Form 926 before we start, as part of the return set it belongs to rather than as a line item you discover afterwards. If the work turns out to be smaller than the quote, the quote is what you pay; if it turns out to be larger, we re-quote before continuing. See the moving to Canada — a newcomer's first return and benefit claims for comparable engagements.

From first call to filed

  1. 1Establish whether the reporting test is met, on the correct measure
  2. 2Assemble the holdings, accounts or entities that fall inside it
  3. 3Prepare the return and reconcile it to the tax return it travels with
  4. 4File, and set the calendar entry so next year is not a catch-up
  • A 24-hour helpline, +1 (416) 619-0068, before you commit to anything.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.
  • Documents move through an access-controlled portal rather than email.

Whatever you have is enough to start the conversation, including nothing but the dates.

Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. General guidance only. Your own facts decide the answer, so bring them to a call before relying on this.

Where form 1116 foreign tax credit comes into this file

If you came here for form 1116 foreign tax credit, this is where it is dealt with. The subject is Form 926, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.

Capitalising the foreign company you just set up is a reportable transfer.

The four phases of the work

  1. Tell us the dates and we will tell you the position

    Arrival, departure, the years in between — the residence question turns on those before anything else.

  2. Fixed fee, defined scope, in writing

    Both agreed before work starts, so the engagement cannot grow into a larger bill.

  3. Prepared together, not passed between firms

    You are not the go-between for two sets of advisers working from two sets of assumptions.

  4. Reviewed, approved, filed

    A named practitioner checks it, you approve it, and then it goes.

The difference a dedicated cross-border team makes

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

The vocabulary this page leans on

Terminal return
The final income tax return of a deceased person, covering income to the date of death and the deemed dispositions arising on it.
Mutual agreement procedure
The treaty process by which two competent authorities resolve a case of double taxation, available even where domestic appeal rights have run.
Source income
Income treated as arising in a particular country by that country's sourcing rules. Sourcing decides who taxes first and therefore who gives credit.
Section 94 trust
A trust deemed resident in Canada because of a resident contributor or beneficiary, bringing its income into the Canadian base.
form 926 transfer foreign corporation: The practitioner's note

Capitalising the foreign company you just set up is a reportable transfer.

Whatever the file turns out to involve, the terms do not move: the scope and the fee are agreed in writing before any work starts, a named practitioner reviews the result, and nothing is filed until you have approved it.

The published fees closest to form 926 transfer foreign corporation

Where earlier capitalisations went unreported, the question becomes how many years have to be brought current and whether a reasonable-cause position is written up alongside them. That is a larger engagement than a single current-year contribution, and it is priced once the history of the transfers has been read.

Corporate cross-border filing

$999fixed, before work starts

Covers: Corporate returns with foreign income, related-party reporting and cross-border structures, for companies of any size.

See this fee page

Transfer pricing documentation

$2,500fixed, before work starts

Covers: Benchmarking and documentation for related-party dealings, prepared to the standard the reviewing authority applies.

See this fee page

The difference a dedicated cross-border team makes

The reporting penalties get named early

The heaviest exposure on a cross-border file is usually a disclosure form, not the tax. We identify which ones apply before a deadline turns into a penalty.

You deal with the person who did the work

The practitioner who prepared and reviewed your file is the one who answers the question about it.

4 global offices

Meet us in person in India, the USA, Canada and the UAE, or send everything through the secure portal — the same process either way.

The quote comes from your documents

Nothing is priced from a phone call. We read what you have first, then the fee is set — so the scope and the number are agreed on the same evidence.

Two of the firm’s advisers at a desk in the Delhi office

How the engagement runs, phase by phase

Step 1

First conversation

We establish what happened and when, because every position here is anchored to a date

Step 2

Written quote

A written scope and a fixed price, so you know the cost before committing

Step 3

Preparation and sign-off

The filings are prepared, cross-checked against each other, and reviewed by name

Step 4

Submission

You see the result, approve it, and we file it

The team at work in the open-plan office

From first document to filed return

  • Step 1: Upload the file as it stands – A secure link arrives after the first call. Incomplete is fine; that is what the review is for.
  • Step 2: The number is settled up front – Priced from your own documents and confirmed in writing before any preparation begins.
  • Step 3: Both returns on one desk – One engagement covers every country the file touches, reconciled line against line.
  • Step 4: Your approval, then the filing – The return is yours to check first. We file once you say so.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

Where to go next

Each of these carries its own guide, pricing pointers and FAQ.

The work we do for clients like this

Safe harbour rules for Indian TP The full guide to safe harbour rules for Indian tp, with the fee fixed before any work starts.
First-year proration schedule — Canada Its own page: first year proration schedule Canada — mechanism, deadlines and published fees.
Form T1248 — residency information schedule Everything on t1248 residency information schedule, at the same depth as this page.
Form 24Q — TDS on salary (India) Form 24q India — the guide, the FAQ and the fixed fee.
Form T1142 — distributions from a non-resident trust The full guide to t1142 distributions non-resident trust, with the fee fixed before any work starts.
Form 14654 — resident certification Its own page: form 14654 resident certification — mechanism, deadlines and published fees.
Scrutiny and reassessment notices for NRIs Everything on scrutiny and reassessment notices for NRIs, at the same depth as this page.
Economic nexus thresholds by state Economic nexus thresholds by state — the guide, the FAQ and the fixed fee.
NRE, NRO and FCNR accounts — how each is taxed The full guide to NRE, NRO and FCNR accounts — how each is taxed, with the fee fixed before any work starts.

Clients who arrive with this exact page

Non-resident landlords — relief you're probably missing The full guide to non-resident landlords relief you're probably missing, with the fee fixed before any work starts.
Tax for coaches & trainers Its own page: coaches & trainers tax — mechanism, deadlines and published fees.
Cross-border truck drivers — what you owe in each country Everything on cross-border truck drivers what you owe in each country, at the same depth as this page.
Influencers & content creators — relief you're probably missing Influencers & content creators relief you're probably missing — the guide, the FAQ and the fixed fee.
Construction & contracting — relief you're probably missing The full guide to construction & contracting relief you're probably missing, with the fee fixed before any work starts.
Software developers — what you owe in each country Its own page: software developers what you owe in each country — mechanism, deadlines and published fees.
Tax for options & futures traders Everything on options & futures traders tax, at the same depth as this page.
Tax for defence contractors Defence contractors tax — the guide, the FAQ and the fixed fee.
Franchise owners — relief you're probably missing The full guide to franchise owners relief you're probably missing, with the fee fixed before any work starts.

Where our clients live and work

Greece tax for expats — country guide The full guide to Greece tax for expats, with the fee fixed before any work starts.
Luxembourg tax for expats — country guide Its own page: Luxembourg tax for expats — mechanism, deadlines and published fees.
Lithuania tax for expats — country guide Everything on lithuania tax for expats, at the same depth as this page.
Italy tax for expats — country guide Italy tax for expats — the guide, the FAQ and the fixed fee.
Ukraine tax for expats — country guide The full guide to Ukraine tax for expats, with the fee fixed before any work starts.
Barbados tax for expats — country guide Its own page: Barbados tax for expats — mechanism, deadlines and published fees.
Austria tax for expats — country guide Everything on Austria tax for expats, at the same depth as this page.
Taiwan tax for expats — country guide Taiwan tax for expats — the guide, the FAQ and the fixed fee.
France tax for expats — country guide The full guide to France tax for expats, with the fee fixed before any work starts.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

What these engagements turn on

Case study 1

Fifteen Per Cent Held Back From a Fee for Services in Canada

A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.

Read how this one runs
Case study 2

Ten Years of Missed Returns Filed as One Engagement

Filing many years at once is a sequencing problem: carry-forwards, instalments and credits from the earliest year feed the latest. Filing them out of order is what turns a recoverable position into an assessed one.

Read how this one runs
Case study 3

A Family Trust Abroad With Reporting on Both Sides

A trust settled in one country and a beneficiary living in another produces reporting for the trust, the settlor and the beneficiary, on different forms and different dates. The engagement maps who files what before anything is prepared.

Read how this one runs
Case study 4

One Salary, Two Countries Claiming It

A US citizen resident in Canada, taxed in full on both sides because each return was prepared without the other in view. Deciding which country has the first right to the income, then claiming relief on the second return in the right order, is what stops the same dollar being taxed twice.

Read how this one runs
Case study 5

Documentation Built to the US Standard

The US requirements differ from the OECD-aligned ones in what has to exist at the time of filing, and a file prepared for one regime can leave the other unprotected. The engagement builds to whichever governs.

Read how this one runs
Case study 6

A Distribution From a Trust Set Up Abroad

A distribution can be capital in the trust's country and income here, and the reporting attaches to the beneficiary rather than the trustee. The work is characterising the payment before it is received where possible.

Read how this one runs
Case study 7

A Penalty Argued on the Facts Rather Than the Form

Reasonable cause is a documented story with dates, not an assertion of good intent. The engagement assembles what the client actually knew and when, and puts the sequence in writing alongside the filings it explains.

Read how this one runs
Case study 8

Two Wills, Two Jurisdictions, One Estate

A will drawn for one country can revoke another or fail to reach assets held abroad. The review checks how each instrument interacts with the other and where probate will actually be required.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Professional Services Firms

Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.

A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.

  • Reg 105 / 102 waivers
  • Permanent establishment risk
  • Partner mobility planning
  • Cross-border withholding recovery
Explore Professional Services

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Form 926 — questions we are asked

Do I file Form 926 even if no tax is owed?

Information return obligations of this kind are generally required on the facts rather than on the tax result, so a nil position does not remove one. US transferors who contribute property to a foreign corporation on formation or afterwards, above the reporting level.

What happens if I have missed Form 926 for several years?

Missed years are dealt with as a package rather than one at a time, because the route chosen for the first year affects the relief available for the rest. We map the years and the obligations before anything is filed.

Is Form 926 the same as the other reports I already file?

No. Reports a US person's transfer of property — cash, shares, intangibles — to a foreign corporation. Satisfying a different obligation, even one covering the same accounts or entity, does nothing for this one.

Should I use a branch or a subsidiary abroad?

A branch is the same legal entity operating in another country, so its profits and losses sit with the parent and it is taxed there as a permanent establishment. A subsidiary is a separate company, taxed in its own right, with dividends and withholding on the way home. Losses, repatriation cost and liability usually decide it, and the answer differs by country pair. See branch vs subsidiary.

Why are corporations double taxed?

Corporate double taxation happens because the company and its owners are separate taxpayers. The company pays tax on its profit; when the after-tax profit is distributed, the shareholder pays tax on the dividend. Canada softens this with the dividend gross-up and credit, which is meant to leave a shareholder roughly where they would have been earning the income directly. The United States taxes the C corporation and then the dividend, with no equivalent integration. See dividends to a foreign parent.

Can I set up a trust that works in two countries?

You can, but the two systems classify and tax trusts differently enough that a structure which is efficient in one is often a reporting problem in the other — a Canadian family trust with a US beneficiary, or a US revocable trust holding Canadian property, are the classic pairs. Canada's twenty-one-year deemed disposition, the US grantor rules and each country's reporting have to be read together, before drafting rather than after. See cross-border wills and trusts.

Meet us in person at any of our offices

Get Form 926 handled for a fixed fee

Describe what happened and which countries are involved; the fee comes back in writing before anything begins.

  • Fixed fees agreed before work starts
  • Re-quoted, never silently invoiced
  • 18,000+ clients served

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

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