Dil Seçin

Form 706-GS(D-1) Talimatlar

Form 706-GS (D-1), Bir Nesil Güvenden Dağıtım Bildirim

Rev. Kasım 2021

İlgili Formlar

Detaylar
Dosya formatı PDF
Boyut 163.7 KB
İndirmek
Department of the Treasury  
Internal Revenue Service  
Instructions for  
Form 706-GS(D-1)  
(Rev. November 2021)  
Use with the October 2008 revision of Form 706-GS(D-1)  
Notification of Distribution From a Generation-Skipping Trust  
Section references are to the Internal Revenue  
Code unless otherwise noted.  
A distribution is not considered a  
taxable distribution if, had it been made  
while an individual was alive, it would  
have been a nontaxable gift because of  
section 2503(e) (relating to transfers  
made for certain educational or medical  
expenses).  
Also, a distribution (or any portion  
thereof) is not a taxable distribution to  
the extent that:  
Trusts  
Nonexplicit trusts. An arrangement  
that has substantially the same effect as  
a trust will be treated as a trust even  
though it is not an explicit trust.  
Future Developments  
For the latest information about  
developments related to Form  
706-GS(D-1) and its instructions, such  
as legislation enacted after they were  
published, go to IRS.gov/Form706-  
Examples of such arrangements are  
insurance and annuity contracts,  
arrangements involving life estates and  
remainders, and estates for years.  
In general, a transfer of property in  
which the identity of the transferee is  
conditioned on the occurrence of an  
event is a transfer in trust. However, this  
rule does not apply to a testamentary  
trust if the event is to occur within 6  
months of the transferor's date of death.  
The property distributed was  
General Instructions  
previously subject to GST tax and  
The distributee in the prior distribution  
is assigned to a generation the same as  
or lower than the distributee in the  
current distribution.  
Purpose of Form  
A trustee uses Form 706-GS(D-1) to  
report certain distributions from a trust  
that are subject to the generation-  
skipping transfer (GST) tax and to  
provide the skip person distributee with  
information needed to figure the tax due  
on the distribution.  
This rule does not apply if the  
transfers have the effect of avoiding  
GST tax for any transfer.  
Nonexplicit trusts do not include  
decedents' estates.  
In the case of a nonexplicit trust, the  
person in actual or constructive  
possession of the property involved is  
considered the trustee and is liable for  
filing Form 706-GS(D-1).  
If you are filing this return for a  
nonexplicit trust, see Line 2a. Trust's  
Employer Identification Number.  
Exceptions  
Irrevocable trusts. The GST tax does  
not apply to any distribution from a trust  
that was irrevocable on September 25,  
1985. Any trust in existence on  
Who Must File  
In general, the trustee of any trust that  
makes a taxable distribution must file a  
Form 706-GS(D-1) for each skip  
September 25, 1985, will be considered  
irrevocable unless:  
person. See Distributions Subject to  
GST Tax, later, for a discussion of what  
constitutes a taxable distribution. The  
trustee must file a return for each skip  
person even if the inclusion ratio  
On September 25, 1985, the value of  
Separate trusts. You must treat the  
the trust could have been included in  
the settlor's gross estate for federal  
estate tax purposes by reason of  
section 2038 if the settlor had died on  
September 25, 1985, or  
following as separate trusts:  
Portions of a trust that are attributable  
to transfers from different transferors  
and  
applicable to the distribution is zero.  
See Column d. Inclusion Ratio.  
Substantially separate and  
Regarding a policy of life insurance  
independent shares of different  
beneficiaries in a trust.  
that is treated as a trust under section  
2652(b), the insured was an owner on  
September 25, 1985, and this would  
have caused the insurance proceeds to  
be included in the insured's gross estate  
for federal estate tax purposes if the  
insured had died on September 25,  
1985.  
When to File  
The trustee must file Copy A of Form  
706-GS(D-1) with the IRS and send  
Copy B to the distributee by April 15th of  
the year following the calendar year  
when the distribution was made. If the  
due date falls on a Saturday, Sunday, or  
legal holiday, file on the next business  
day.  
You must report such separate trusts  
under different item numbers in column  
a of line 3, even if they have the same  
inclusion ratios.  
Distributions Subject to  
GST Tax  
For more information, see  
In general, all taxable distributions are  
subject to the GST tax. A taxable  
distribution is any distribution from a  
trust to a skip person (other than a  
taxable termination or a direct skip).  
Regulations section 26.2601-1(b).  
Where To File  
Trusts containing qualified termina-  
ble interest property. If an irrevocable  
trust in existence on September 25,  
1985, holds qualified terminable interest  
property (QTIP) (as defined in section  
2056(b)(7)) as a result of an election  
under section 2056(b)(7) or 2523(f), the  
trust may elect to be treated for  
The trustee must send Copy A of Form  
706-GS(D-1) to the following address:  
Department of the Treasury  
Internal Revenue Service Center  
Stop 824G  
If any GST tax imposed on a  
distribution is paid out of the trust from  
which the distribution was made, the  
amount of tax paid by the trust is also a  
taxable distribution.  
7940 Kentucky Drive  
Florence, KY 41042-2915  
purposes of the GST tax as if the QTIP  
Sep 09, 2021  
Cat. No. 10926L  
election had not been made. Thus,  
transfers from such a trust will not be  
subject to the GST tax.  
decimal places (for example,  
“0.00001”).  
Transition Rule in Case of  
Mental Disability  
Transition Rule for Revocable  
Trusts  
The GST tax will not apply to any  
distributions from a revocable trust,  
provided:  
If the settlor was under a disability on  
October 22, 1986, the GST tax may not  
apply. See Regulations section  
Additions to irrevocable trusts. To  
the extent that a distribution from a trust  
is from an addition to an irrevocable  
trust made after September 25, 1985,  
such distribution is subject to the GST  
tax. Additions include constructive  
additions described in Regulations  
section 26.2601-1(b)(1)(v).  
For purposes of figuring the inclusion  
ratio (defined later), use only the value  
of the total additions made to the trust  
after September 25, 1985.  
26.2601-1(b)(3) for a definition of the  
term “mental disability” and details on  
the application of this rule.  
1. The trust was executed before  
Exceptions to Additions Rule  
October 22, 1986;  
Do not treat as an addition to a trust any  
addition that is made pursuant to an  
instrument or arrangement that is  
covered by the rules discussed earlier  
under Transition Rule for Revocable  
Trusts and Transition Rule in Case of  
Mental Disability. This also applies to  
inter vivos transfers if the same property  
would have been added to the trust by  
such an instrument. For examples  
illustrating this rule, see Regulations  
section 26.2601-1(b)(4)(ii).  
2. The trust as it existed on October  
21, 1986, was not amended after  
October 21, 1986, in any way that  
created or increased the amount of a  
generation-skipping transfer;  
3. Except as provided later, no  
Distributions from trusts to which  
additions have been made. As  
described earlier, when an addition is  
made after September 25, 1985, to an  
irrevocable trust, only the portion of the  
trust resulting from the addition is  
subject to the GST tax. For distributions,  
this portion is the product of the  
allocation fraction and the value of the  
property distributed (including  
addition was made to the trust; and  
4. The settlor died before January 1,  
1987.  
A revocable trust is any trust that on  
October 22, 1986, was not an  
irrevocable trust (as defined earlier) and  
would not have been an irrevocable  
trust had it been created before  
September 25, 1985.  
Definitions  
Skip persons. For GST tax purposes,  
skip person means:  
accumulated income and appreciation  
on that property).  
The instructions under Trusts  
1. A natural person assigned to a  
generation that is two or more  
generations below the settlor's  
generation, or  
containing qualified terminable interest  
property apply also to revocable trusts  
covered by these transition rules.  
The allocation fraction is a fraction,  
the numerator of which is the value of  
the addition as of the date it was made  
(regardless of whether it was subject to  
gift or estate tax, but reduced by the  
amount of federal or state estate or gift  
tax imposed and paid by the trust). The  
denominator of the fraction is the fair  
market value of the entire trust  
2. A trust that meets the following  
Amendments to revocable trusts. An  
amendment to a revocable trust in  
existence on October 21, 1986, will not  
be considered to result in the creation of  
or an increase in the amount of a  
conditions:  
a. All interests in the trust are held  
by skip persons, or  
b. No person holds an interest in the  
trust, and at no time after the transfer to  
the trust may a distribution be made to a  
non-skip person.  
generation-skipping transfer where:  
immediately after the addition, less any  
trust amount that is similar to expenses,  
indebtedness, or taxes that would be  
allowable as a deduction under section  
2053, and further reduced by the same  
amount that the numerator was reduced  
by to reflect federal or state estate or gift  
taxes paid by the trust.  
When there is more than one  
addition, the allocation fraction is  
revised after each addition. The  
numerator of the revised fraction is the  
sum of:  
The amendment is administrative or  
clarifying in nature; or  
It is designed to perfect a marital or  
charitable deduction for an existing  
transfer, and it only incidentally  
increases the amount transferred to a  
skip person.  
Non-skip person. A non-skip person is  
any person who is not a skip person.  
Generation assignment. A generation  
is determined along family lines as  
follows:  
Addition to revocable trusts. If an  
addition (including a constructive  
addition) to a revocable trust is made  
after October 21, 1986, and before the  
death of the settlor, all subsequent  
distributions from the trust will be  
subject to the GST tax, provided the  
other requirements of taxability are met.  
For settlors dying before January 1,  
1987, any addition made to a revocable  
trust after the death of the settlor will be  
treated as if made to an irrevocable  
trust.  
1. Where the beneficiary is a lineal  
descendant of a grandparent of the  
transferor (for example, the donor's  
cousin, niece, nephew, etc.), the  
number of generations between the  
transferor and the descendant is  
determined by subtracting the number  
of generations between the grandparent  
and the transferor from the number of  
generations between the grandparent  
and the descendant.  
1. The value of the trust subject to  
the GST tax immediately before the last  
addition and  
2. The amount of the latest addition.  
The denominator of the revised  
fraction is the total value of the entire  
trust immediately after the latest  
2. Where the beneficiary is the lineal  
descendant of a grandparent of a  
spouse (or former spouse) of the  
transferor, the number of generations  
between the transferor and the  
See Regulations section  
26.2601-1(b)(2)(vii) for examples  
demonstrating the operation of these  
rules.  
addition. If the addition results from a  
generation-skipping transfer, reduce the  
numerator and denominator by the  
amount of any GST tax imposed on the  
transfer and recovered from the trust.  
Round off the allocation fraction to five  
descendant is determined by  
subtracting the number of generations  
between the grandparent and the  
-2-  
spouse (or former spouse) from the  
number of generations between the  
grandparent and the descendant.  
3. For this purpose, a relationship  
by adoption is considered a blood  
relationship. A relationship by half-blood  
is considered a relationship by whole  
blood.  
4. The spouse or former spouse of a  
transferor or lineal descendant is  
considered to belong to the same  
generation as the transferor or lineal  
descendant, as the case may be.  
great-grandchildren who are lineal  
descendants of the deceased  
grandchild are considered your  
grandchildren for purposes of the GST  
tax.  
If someone prepares your return and  
does not charge you, that person should  
not sign the return. Generally, anyone  
who is paid to prepare your return must  
sign it in the space indicated.  
This rule also governs generation  
assignment for other lineal  
Specific Instructions  
descendants. For example, if property is  
transferred to an individual who is a  
descendant of a parent of the transferor,  
and that individual's parent (who is a  
lineal descendant of the parent of the  
transferor) is deceased at the time the  
transfer is subject to gift or estate tax,  
then for purposes of generation  
assignment, the individual is treated as  
if he or she is a member of the  
Part I—General  
Information  
Line 1a. Skip Person  
Distributee's Identifying  
Number  
Enter the social security number of an  
individual distributee. (If the number is  
unknown or the individual has no  
number, indicate “unknown” or “none.”)  
If the distributee is a trust, enter the  
trust's employer identification number  
(EIN).  
A person who is not assigned to a  
generation according to the rules above  
is assigned to a generation based on his  
or her birth date as follows.  
generation that is one generation below  
the lower of:  
1. A person who was born not more  
than 121/2 years after the transferor is in  
the transferor's generation.  
The transferor's generation or  
The generation assignment of the  
youngest living ancestor of the  
individual, who is also a descendant of  
the parent of the transferor.  
2. A person born more than 121/2  
years, but not more than 371/2 years,  
after the transferor is in the first  
Line 2a. Trust's Employer  
Identification Number  
Enter the EIN of the trust from which the  
distribution was made.  
The same rules apply to the  
generation assignment of any  
descendant of the individual.  
This rule does not apply to a transfer  
to an individual who is not a lineal  
descendant of the transferor if the  
transferor has any living lineal  
descendants.  
If any transfer of property to a trust  
would have been a direct skip except for  
this generation assignment rule, then  
the rule also applies to transfers from  
the trust attributable to such property.  
generation younger than the transferor.  
3. Similar rules apply for a new  
generation every 25 years.  
A nonexplicit trust as described  
under Who Must File must have an EIN  
that is separate from any other entity's  
EIN and that will be used only by the  
nonexplicit trust.  
If more than one of the rules for  
assigning generations applies to a  
beneficiary, the beneficiary is generally  
assigned to the youngest of the  
generations that apply.  
If an entity such as a partnership,  
corporation, trust, or estate has an  
interest in the property, each individual  
who has a beneficial interest in the  
entity is treated as having an interest in  
the property. The individual is then  
assigned to a generation using the rules  
described above.  
A trust or nonexplicit trust that does  
not have an EIN should apply for one on  
Form SS-4, Application for Employer  
Identification Number. You can get  
Form SS-4, and other IRS tax forms and  
publications, by visiting IRS.gov/Forms.  
Ninety-day rule. For purposes of  
determining if an individual's parent is  
deceased at the time of a testamentary  
transfer, an individual's parent who dies  
no later than 90 days after a transfer  
occurring by reason of the death of the  
transferor is treated as having  
Send Form SS-4 to the address  
listed under Where To File. If the EIN  
has not been received by the filing time  
for the GST form, write “Applied for” on  
line 2a.  
Governmental entities and certain  
charitable organizations are assigned to  
the transferor's generation. Distributions  
to them will never be  
predeceased the transferor. The 90-day  
rule applies to transfers occurring on or  
after July 18, 2005. See Regulations  
section 26.2651-1 for more information.  
generation-skipping transfers.  
Part II—Distributions  
Generation assignment where inter-  
vening parent is deceased. If you  
made a gift or bequest to your  
Report all taxable distributions made  
during the year from the trust listed on  
line 2 to the skip person distributee  
listed on line 1. Report a distribution  
even if its inclusion ratio is zero.  
Multiple skips. If after a  
grandchild and at the time you made the  
gift or bequest, the grandchild's parent  
(who is your or your spouse's or your  
former spouse's child) is deceased,  
then for purposes of generation  
assignment, your grandchild will be  
considered to be your child rather than  
your grandchild. Your grandchild's  
children will be treated as your  
generation-skipping transfer the  
property transferred is held in trust, then  
for the purpose of determining the  
taxability of subsequent distributions  
from the trust involving that property, the  
settlor of the property is assigned to the  
first generation above the highest  
generation of any person who has an  
interest in the trust immediately after the  
initial transfer.  
Column a. Item No.  
Assign consecutive numbers to each  
distribution made during the year.  
Different items of property having  
different inclusion ratios must be listed  
separately in Part II. Include under a  
single item number any properties  
having the same inclusion ratio even if  
they were distributed at different times.  
An exception to this is distributions from  
“separate trusts” as that term was  
defined earlier. You must report  
grandchildren rather than your  
great-grandchildren.  
This rule is also applied to your lineal  
descendants below the level of  
grandchild. For example, if your  
grandchild is deceased, your  
Signature  
The trustee, or an authorized  
representative of the trustee, must sign  
Form 706-GS(D-1).  
distributions from such separate trusts  
-3-  
under different item numbers even if  
they have the same inclusion ratio.  
Once made, allocations are  
irrevocable.  
Allocation of the GST exemption is  
made by the settlor on Form 709, United  
States Gift (and Generation-Skipping  
Transfer) Tax Return, and/or Form 706,  
United States Estate (and  
Applicable fraction. The applicable  
fraction is a fraction, the numerator of  
which is the amount of the GST  
exemption allocated to the trust. The  
denominator of the fraction is:  
Column b. Description of  
Property  
Real estate. Describe the real estate in  
enough detail so that the IRS can easily  
locate it for inspection and valuation.  
For each parcel of real estate, report the  
location and, if the parcel is improved,  
describe the improvements. For city or  
town property, report the street number,  
ward, subdivision, block and lot, etc. For  
rural property, report the township,  
range, landmarks, etc.  
1. The value of the property  
transferred to the trust, minus  
Generation-Skipping Transfer) Tax  
Return, by the executor of the settlor's  
estate. Therefore, you should obtain  
information regarding the allocation of  
the exemption to this trust from the  
settlor or the executor of the settlor's  
estate, as applicable.  
If the settlor's entire GST exemption  
is not allocated by the due date  
(including extensions) of the settlor's  
estate tax return, the exemption is  
automatically allocated under the rules  
of section 2632.  
Transfers subject to an estate tax in-  
clusion period. If a transferor made an  
inter vivos transfer, and the property  
transferred would have been includible  
in the transferor's estate if he or she had  
died immediately after the transfer  
(other than by reason of the transferor  
dying within 3 years of making the gift),  
for purposes of determining the  
2. The sum of:  
a. Any federal estate tax or state  
death tax actually recovered from the  
trust attributable to the property and  
b. Any charitable deduction allowed  
under section 2055 or 2522 with respect  
to the property.  
Stocks and bonds. For stocks, give:  
Round the applicable fraction to at  
least the nearest one-thousandth (for  
example, “0.001”).  
Number of shares;  
Whether common or preferred;  
Issue;  
Numerator (GST exemption). Every  
individual settlor is allowed a lifetime  
GST exemption to be allocated against  
property that the individual has  
transferred. For generation-skipping  
transfers made through 1998, the  
exemption was $1 million. The GST  
exemption amounts thereafter are as  
follows:  
Par value where needed for  
valuation;  
Price per share;  
Exact name of corporation;  
Principal exchange upon which sold,  
if listed on an exchange; and  
CUSIP number.  
For bonds, give:  
Quantity and denomination;  
Name of obligor;  
Year  
1999  
2000  
2001  
2002  
2003  
2004 and 2005  
2006–2008  
2009  
Amount  
$1,010,000  
$1,030,000  
$1,060,000  
$1,100,000  
$1,120,000  
$1,500,000  
$2,000,000  
$3,500,000  
$5,000,000  
$5,120,000  
$5,250,000  
$5,340,000  
$5,430,000  
$5,450,000  
$5,490,000  
$11,180,000  
$11,400,000  
$11,580,000  
$11,700,000  
inclusion ratio, an allocation of GST  
exemption will only become effective at  
the close of the estate tax inclusion  
period (ETIP).  
The value of the property for the  
purpose of figuring the inclusion ratio is  
the estate tax value if the property is  
included in the transferor's gross estate,  
or its value at the close of the ETIP.  
Date of maturity;  
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Interest rate;  
Interest due date;  
Principal exchange, if listed on an  
exchange; and  
CUSIP number.  
.
.
If the stock or bond is unlisted, show  
.
.
.
.
.
.
the company's principal business office.  
2010 and 2011  
The CUSIP (Committee on Uniform  
Security Identification Procedure)  
number is a nine-digit number that is  
assigned to all stocks and bonds traded  
on major exchanges and many unlisted  
securities. Usually the CUSIP number is  
printed on the face of the stock  
2012  
2013  
2014  
2015  
2016  
2017  
2018  
2019  
2020  
2021  
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
The ETIP closes at the earliest of:  
1. The time the transferred property  
would no longer be includible in the  
settlor's estate,  
2. The date of a generation-  
skipping transfer of the property, or  
certificate. If the CUSIP number is not  
printed on the certificate, it may be  
obtained through the company's  
transfer agent.  
Other personal property. Any  
personal property distributed must be  
described in enough detail that the IRS  
can value it.  
3. The date of death of the settlor.  
Denominator (valuation of trust as-  
sets). In general, the value to be used  
in the applicable fraction is the gift tax  
value for an inter vivos transfer as long  
as the allocation of the GST exemption  
was made on a timely filed gift tax  
A valid Deceased Spousal  
Unused Exclusion Amount  
(“DSUE ” or portability) election  
!
CAUTION  
return. The value of a testamentary  
Column d. Inclusion Ratio  
Note. The trustee must provide the  
inclusion ratio for every distribution.  
All distributions, or any part of a single  
distribution, that have different inclusion  
ratios must be listed as separate items  
in column a.  
by an executor of a deceased spouse's  
estate does not apply to or impact GST  
tax exemption.  
transfer is generally the estate tax value.  
If the allocation of the exemption to  
an inter vivos transfer, made before  
January 1, 2001, is not made on a  
timely filed gift tax return, the value for  
purposes of the applicable fraction is  
the value of the property transferred at  
the time the allocation is filed with the  
IRS.  
For existing trusts, transferors may  
allocate the additional GST exemption  
amount attributable to section 2631(c)  
increases if they otherwise qualify under  
the existing rules for late allocations. For  
more information, see section 2632 and  
Multiple transfers into a trust, later.  
The inclusion ratio is the excess of 1  
over the applicable fraction determined  
for the trust from which the distribution  
was made.  
-4-  
Qualified terminable interest  
property. For qualified terminable  
interest property (QTIP) that is included  
in the estate of the surviving spouse of  
the settlor because of section 2044,  
unless a special QTIP election has been  
made under section 2652(a)(3), the  
surviving spouse is considered the  
transferor under section 2652(a) for  
GST purposes, and the value is the  
estate tax value in the estate of the  
surviving spouse.  
A special QTIP election allows  
property for which a QTIP election was  
made for estate or gift tax purposes to  
be treated for GST tax purposes as if  
this QTIP election had not been made. If  
the special QTIP election has been  
made, the predeceased settlor spouse  
is the transferor and the value is that  
spouse's estate or gift tax value under  
the rules described above. Either the  
settlor spouse or the executor of the  
settlor spouse's estate must make the  
special QTIP election.  
attributable to such property) and any  
charitable deduction allowed with  
respect to such property and  
2. The value of all property in the  
trust immediately before the current  
transfer.  
Paperwork Reduction Act Notice.  
We ask for the information on this form  
to carry out the Internal Revenue laws of  
the United States. You are required to  
give us the information. We need it to  
ensure that you are complying with  
these laws and to allow us to figure and  
collect the right amount of tax.  
Charitable lead annuity trusts. For  
distributions from a charitable lead  
annuity trust, the numerator of the  
applicable fraction is the adjusted GST  
exemption as defined below. The  
denominator is the value of the trust  
immediately after termination of the  
charitable lead annuity.  
You are not required to provide the  
information requested on a form that is  
subject to the Paperwork Reduction Act  
unless the form displays a valid OMB  
control number. Books or records  
relating to a form or its instructions must  
be retained as long as their contents  
may become material in the  
The adjusted GST exemption is the  
sum of:  
administration of any Internal Revenue  
law. Generally, tax returns and return  
information are confidential, as required  
by section 6103.  
1. The exemption allocated to the  
trust and  
2. Interest on the exemption  
determined at the interest rate used to  
figure the estate or gift deduction for the  
charitable lead annuity and for the  
actual period of the charitable lead  
annuity.  
The time needed to complete and file  
this form will vary depending on  
individual circumstances. The estimated  
average time is:  
ETIP. If an individual could not make  
a timely allocation of exemption  
In the case of a late allocation, the  
amount of interest accrued prior to the  
date of allocation is zero.  
Recordkeeping. . . . .  
1 hr., 33 min.  
1 hr., 46 min.  
42 min.  
because of an ETIP, the value of the  
property for the purpose of computing  
the inclusion ratio is the estate tax value  
if the property is includible in the  
Learning about the  
law or the form . . .  
Column e. Value  
Enter the value of the property  
distributed from the trust at the time of  
distribution.  
Preparing the  
form . . . . . . . . . . .  
transferor's gross estate. If the property  
is not includible in the transferor's gross  
estate, the property is valued at the  
close of the ETIP, provided that the GST  
exemption is allocated on a timely filed  
gift tax return for the calendar year in  
which the ETIP closes.  
Copying,  
assembling, and  
sending the form  
to the IRS . . . . . . .  
Part III—Trust Information  
Line 4  
20 min.  
An arrangement that has substantially  
the same effect as a trust will be treated  
as a trust even though it is not an  
explicit trust. Examples of such  
Multiple transfers into a trust. When  
a transfer is made to a pre-existing trust,  
the applicable fraction must be  
We welcome your comments about  
these instructions and your suggestions  
for future editions. You can send us  
comments through IRS.gov/  
recomputed. The numerator of the new  
fraction is the sum of:  
arrangements are insurance and  
annuity contracts, arrangements  
involving life estates and remainders,  
and estates for years. Nonexplicit trusts  
do not include decedent's estates.  
FormsComments. Or, you can write to  
the Internal Revenue Service, Tax  
Forms and Publications, 1111  
1. The exemption allocated to the  
current transfer and  
2. The nontax portion of the trust  
immediately before the current transfer  
(the product of the applicable fraction  
and the value of all of the property in the  
trust immediately before the current  
transfer).  
Constitution Ave. NW, IR-6526,  
Washington, DC 20224.  
In the case of a nonexplicit trust, the  
trustee is the person in actual or  
constructive possession of the property  
involved.  
Although we can't respond  
individually to each comment received,  
we do appreciate your feedback and will  
consider your comments as we revise  
our tax forms, instructions, and  
publications. Do not send the tax form to  
this address. Instead, see Where To  
File.  
Line 5  
The denominator of the new fraction  
is the sum of:  
1. The value of the current transfer  
(minus any federal estate tax or state  
death tax actually paid by the trust  
Whenever property is transferred into a  
pre-existing trust, the inclusion ratio  
must be refigured. See Multiple  
transfers into a trust for the rule on how  
to refigure the inclusion ratio.  
-5-