T.D. 9525, 2011-23 I.R.B. 837, finalizes regulations that affect U.S. persons that transfer property subject to lease of aircraft or vessels in foreign commerce to a foreign corporation. Such transfers are reported on the “property to be leased” line of Form 926, Part III. Furthermore, such U.S. persons would also be required to complete Form 926, Part IV, line 13.

Section 512 of the Hiring Incentives to Restore Employment Act of 2010 provided a new penalty for underpayments attributable to undisclosed foreign financial asset understatements. For more information, see Section 6662(j) Penalty below.