On 19 November 2014, the U.S. IRS published in the Federal Register TD 9704: Failure To File Gain Recognition Agreements or Satisfy Other Reporting Obligations. TD 9704 contains final and temporary regulations necessary to update and clarify the rules that apply when a U.S. or foreign person fails to file gain recognition agreements (GRAs) or related documents or to satisfy other reporting obligations in regard to certain transfers of property to foreign corporations in nonrecognition exchanges.   The regulations, which are effective from 19 November 2014, include the following: A U.S. transfer is now required to report on Form 926 detailed...