Sections 367(e)(1) and 367(e)(2) provide for gain recognition on certain transfers to foreign persons under sections 355 and 332. Section 6038B(a) requires U.S. persons transferring property to foreign persons in exchanges described in sections 332 and 355 to furnish information regarding such transfers.
The latest form for Failure To File Gain Recognition Agreements or Satisfy Other Reporting Obligations expires 2023-08-31 and can be found here.