Comment
Level 1

Per the IRS instructions for the Form 926: "Who Must File: Generally, a U.S. citizen or resident, a domestic corporation, or a domestic estate or trust must complete and file Form 926 to report certain transfers of property to a foreign corporation that are described in section 6038B(a)(1)(A), 367(d), or 367(e)."

No partnership filing of the Form 926 is required.