If the purchaser or seller is a controlled foreign corporation (CFC), each U.S. shareholder should attach Form 8594 to its Form 5471. Exceptions. Form 8594 is a tax document required in certain business sales where the buyer acquires assets rather than stock or equity.Who Must File Form 8594? Both the seller and purchaser of a group of assets that make up a trade or business need to file Form 8594. The burden for this requirement is reflected in the burden of Form 8594. Allocating the Purchase Price. Attachment A is Form 8594. Attachment B is the new Form 8883.