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 |