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Old 09-29-2015, 04:08 PM
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Property owned by C-Corp

I have a foreign entity in Spain that owns 100% of a US C Corp. The US C-Corp sells tangible goods. They also own the building that they are in. I want to transfer the property and have the Spain Company own the building. Do you know what the tax implications would be?



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Old 09-29-2015, 07:41 PM
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i guerss this is not usual case;Transfers of property from the United States to a foreign sub is taxable UNLESS the transfers are in connection with Complete liquidations of subsidiaries; Transfer to corporation controlled by transferor; Exchanges of stock and securities in certain reorganizations; Receipt of additional consideration; Nonrecognition of gain or loss to corps; treatment of distributions. No gain / loss shall be recognized to a corp if such corp is a party to a reorganization and exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corp a party to the reorganization. for more info you can contact an IRS intl taxation representative



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