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Форма 706-NA Інструкція

Інструкція по формуванню 706-NA, Сполучених Штатів Америки (і Generation-Skipping Transfer) Повернутися (Схід нерезидента не громадянина США)

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  • Форма 706-НА - Сполучені Штати Америки (і Generation-Skipping Transfer) Повернути нерухомість нерезидента США
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Department of the Treasury  
Internal Revenue Service  
Instructions for Form 706-NA  
(Rev. October 2022)  
United States Estate (and Generation-Skipping Transfer) Tax Return  
Estate of nonresident not a citizen of the United States  
Section references are to the Internal Revenue Code  
unless otherwise noted.  
by the beneficiary. To satisfy the consistent basis  
reporting requirements, the estate must file Form 8971,  
Information Regarding Beneficiaries Acquiring Property  
From a Decedent. See Form 8971 and its instructions.  
Future Developments  
For the latest information about developments related to  
Form 706-NA and its instructions, such as legislation  
enacted after they were published, go to IRS.gov/  
Estate Tax Closing Letters  
An estate tax closing letter (ETCL) will not be issued  
unless a request is made via Pay.gov. To allow time for  
processing, please wait at least 9 months after filing Form  
706-NA to request an estate tax closing letter.  
ETCL fee. Effective October 28, 2021, final regulations  
TD 9957 established a user fee of $67 for persons  
requesting the issuance of an ETCL. To make an ETCL  
request after October 28, 2021, you must go to Pay.gov to  
submit a request and pay the user fee. Go to Frequently  
instructions and more information related to ETCLs.  
Account transcripts in lieu of ETCL. Instead of an  
ETCL, the executor of the estate may request an account  
transcript, which reflects transactions including the  
acceptance of Form 706-NA or the completion of an  
examination. Account transcripts are available online to  
registered tax professionals using the Transcript Delivery  
System (TDS) or to authorized representatives making  
requests using Form 4506-T. Go to Transcripts in Lieu of  
Estate Tax Closing Letters for specific instructions to  
request online transcripts using the TDS or hardcopy  
transcripts using Form 4506-T.  
What’s New  
Estate tax closing letter fee. Effective October 28,  
2021, a user fee of $67 was established for persons  
requesting the issuance of an estate tax closing letter  
(ETCL). See ETCL fee, later, for more information.  
General Instructions  
Purpose of Form  
Form 706-NA is used to compute estate and  
generation-skipping transfer (GST) tax liability for  
nonresident not a citizen (NRNC) decedents. The estate  
tax is imposed on the transfer of the decedent's taxable  
estate rather than on the receipt of any part of it.  
For information about transfer certificates for U.S.  
assets, write to the following address.  
Internal Revenue Service  
Attn: E&G, Stop 824G  
7940 Kentucky Drive  
The following definitions apply in these instructions.  
United States. The United States means the 50 states  
Florence, KY 41042-2915  
and the District of Columbia.  
Domicile. For estate tax purposes, a person acquires  
domicile in a place by living there, for even a brief period  
of time, with no definite present intention of later moving.  
For this purpose, the United States includes only the  
states and the District of Columbia. See Regulations  
section 20.0-1 for more information.  
Nonresident not a citizen (NRNC) of the United  
States. For estate tax purposes, a decedent is an NRNC  
of the United States if the decedent is neither domiciled in  
nor a citizen of the United States at the time of death. A  
decedent who acquired U.S. citizenship solely by reason  
of being a citizen of a U.S. territory or by reason of birth or  
residence within a U.S. territory is not treated as a U.S.  
Note. In order to complete this return, you must obtain  
Form 706, United States Estate (and Generation-Skipping  
Transfer) Tax Return, and its instructions. You must attach  
schedules from Form 706 if you intend to claim a marital  
deduction, a charitable deduction, a qualified  
conservation easement exclusion, or a credit for tax on  
prior transfers, or if you answer “Yes” to question 5, 7, 8,  
9a, 9b, or 11 in Part III. General Information. You will need  
the Instructions for Form 706 to explain how to value  
stocks and bonds. Make sure that you use the version of  
Form 706 that corresponds to the date of the decedent's  
Consistent Basis Reporting  
Estates are required to report to the IRS and the recipient  
the estate tax value of each asset included in the gross  
estate within 30 days of filing Form 706-NA, or earlier if  
the return is filed late. The basis of certain assets when  
sold or otherwise disposed of must be consistent with the  
basis (estate tax value) of the asset when it was received  
Note. A decedent may be a U.S. resident for income tax  
purposes yet be considered a nonresident for estate tax  
Long-term U.S. resident. A long-term U.S. resident is  
an individual (other than a U.S. citizen) who has been a  
Sep 19, 2022  
Cat. No. 63118N  
lawful permanent resident of the United States (green  
card holder) for income tax purposes in at least 8 of the  
last 15 tax years ending with the tax year in which U.S.  
income tax residency is terminated. See section 877(e) for  
more information.  
Executor. An executor is the personal representative,  
executor, executrix, administrator, or administratrix of the  
deceased person's estate. If no executor is appointed,  
qualified, and acting in the United States, every person in  
actual or constructive possession of any of the decedent's  
property must file a return. If more than one person must  
file, it is preferable that they join in filing one complete  
return. Otherwise, each must file as complete a return as  
possible, including a full description of the property and  
each person's name who holds an interest in it.  
Executors must provide documentation proving their  
status. Documentation will vary but may include a certified  
copy of the will or a court order designating the  
executor(s). A statement by the executor(s) attesting to  
their status is insufficient.  
U.S. expatriate. Special estate tax rules may apply to  
decedents who expatriated from the United States prior to  
death. For these purposes, both U.S. citizens who  
relinquished their citizenship and long-term residents who  
have surrendered their green card or taken a position  
under a tax treaty that they are solely a resident of the  
other country, are treated as expatriates.  
For decedents who expatriated prior to June 17, 2008,  
and were still subject to the 10-year alternative tax regime  
of section 877(b) on the date of death, the rules in section  
2107 apply to determine the value of the decedent’s U.S.  
taxable estate. For decedents who expatriated on or after  
June 17, 2008, and were “covered expatriates” on the  
date of death, as defined in section 877A(g)(1), the rules  
in section 2107 do not apply, but the rules of section 2801  
may apply. So decedents who expatriated on or after  
June 17, 2008, are generally subject to U.S. estate tax as  
all other NRNC decedents, and the references to “U.S.  
expatriate” in these instructions refer only to decedents  
who expatriated prior to June 17, 2008. See the  
sections 877 and 2107 and Form 8854 as they existed in  
the relevant tax year for additional information.  
Who Must File  
The executor must file Form 706-NA if the date of death  
value of the decedent’s U.S.-situated assets, together  
with the gift tax specific exemption and the amount of  
adjusted taxable gifts, exceeds the filing threshold of  
$60,000. The gift tax specific exemption refers to the  
amount allowed for gifts made by the decedent between  
September 9, 1976, and December 31, 1976, inclusive.  
The amount of adjusted taxable gifts refers to the amount  
of adjusted taxable gifts made by the decedent after  
December 31, 1976.  
When To File  
File Form 706-NA within 9 months after the date of death  
unless an extension of time to file was granted.  
If you are unable to file Form 706-NA by the due date,  
use Form 4768, Application for Extension of Time To File  
a Return and/or Pay U.S. Estate (and  
Generation-Skipping Transfer) Taxes, to apply for an  
automatic 6-month extension of time to file. If you have  
already received a 6-month extension and are an  
executor who is out of the country, you may apply for an  
additional extension of time to file by filing a second Form  
4768 and completing the form and attaching a written  
statement of explanation as instructed. For both  
extensions, check the “Form 706-NA” box in Part II of  
Form 4768.  
Private delivery services (PDSs). You can use certain  
PDSs designated by the IRS to meet the "timely mailing  
as timely filing/paying" rule for tax returns and payments.  
Go to IRS.gov/PDS for the current list of designated  
The PDS can tell you how to get written proof of the  
mailing date.  
For the IRS mailing address to use if you're using a  
PDSs can’t deliver items to P.O. boxes. You must  
instructions for Question 6a and Question 6b, later. Also,  
see effective dates, later, for more information.  
Expatriation after June 3, 2004, but before June 17,  
2008. A decedent would have been subject to the  
10-year alternative tax regime of section 877(b) if the  
individual met one of three tests set out under section  
877(a) relating to:  
use the U.S. Postal Service to mail any item to an  
IRS P.O. box address.  
Where To File  
File Form 706-NA at the following address.  
Department of the Treasury  
Internal Revenue Service Center  
Kansas City, MO 64999  
1. Average annual net income tax liability,  
2. Net worth, and  
If using a PDS, use this address.  
3. Certification of tax compliance.  
See sections 877 and 2107 and Form 8854, Initial and  
Annual Expatriation Statement, as they existed in the  
relevant tax year for additional information.  
Expatriation on or after February 6, 1995, through  
June 3, 2004. A decedent would have been presumed to  
be subject to the 10-year alternative tax regime of section  
877(b) if the individual's average annual net income tax  
liability or net worth exceeded certain limits, absent a  
private letter ruling reversing the presumption. See  
Internal Revenue Submission Processing Center  
333 W. Pershing  
Kansas City, MO 64108  
Section 6651 provides for penalties for both late filing of  
returns and late payment of tax unless there is reasonable  
cause for the delay. There are also penalties for willful  
attempts to evade or defeat payment of tax.  
Instructions for Form 706-NA (Rev. 10-2022)  
The law also provides for penalties for valuation  
understatements that cause an underpayment of tax. See  
sections 6662(g) and (h) for more details.  
Specific Instructions  
Reasonable-cause determinations. If you receive a  
notice about penalties after you file Form 706-NA, send an  
explanation, and we will determine if you meet  
If the decedent died testate (with a legally valid will),  
attach a certified copy of the will to Form 706-NA. If you  
are unable to obtain a certified copy, attach a copy of the  
will and explain why it could not be certified.  
reasonable-cause criteria. Do not attach an explanation  
when you file Form 706-NA. Explanations attached to the  
return at the time of filing will not be considered.  
You must also attach a copy of the decedent's death  
Return preparer. Estate tax return preparers who  
prepare any return or claim for refund that reflects an  
understatement of tax liability due to an unreasonable  
position are subject to a penalty equal to the greater of  
$1,000 or 50% of the income earned (or to be earned) for  
the preparation of each such return. Estate tax return  
preparers who prepare any return or claim for refund that  
reflects an understatement of tax liability due to willful or  
reckless conduct are subject to a penalty of $5,000 or  
75% of the income earned (or income to be earned),  
whichever is greater, for the preparation of each such  
return. See section 6694(a) and 6694(b), the related  
regulations, and Announcement 2009-15, 2009-11 I.R.B.  
687, available at Announcement 2009-15, for more  
For closely held or inactive corporate stock, attach the  
balance sheets, particularly the one nearest the valuation  
date, and statements of the net earnings or operating  
results and dividends paid for each of the 5 preceding  
years. Attach any other documents, such as appraisals,  
needed for explanation. Also attach copies of all available  
U.S. gift tax returns the decedent filed. Other documents  
may be required as explained in these instructions.  
Attach an English translation to all documents in other  
Part I. Decedent, Executor, and  
Death Tax Treaties  
Line 2. Enter the decedent's social security number  
(SSN), if applicable, or the decedent's individual taxpayer  
identification number (ITIN), but only if the decedent had  
previously used the ITIN to file other U.S. tax returns. If the  
decedent does not have an SSN or a previously used  
ITIN, the IRS will assign an Internal Revenue Service  
Number (IRSN) to the decedent. If the decedent has  
already been assigned an IRSN, please enter the number  
on line 2. If the decedent does not have an SSN, ITIN, or  
an IRSN, leave line 2 blank.  
Death tax treaties are in effect with the following countries.  
South Africa  
United Kingdom  
Part III. General Information  
*Article XXIX B of the United States–Canada Income Tax Treaty  
Authorization. Completing the authorization permits the  
attorney, accountant, enrolled agent, or other  
representative indicated to represent the estate before the  
IRS and receive confidential tax information. It will not  
authorize the representative to enter into closing  
agreements for the estate.  
If you intend for the representative to represent the  
estate before the IRS, the representative must complete  
and sign this authorization. If you would like to authorize  
your representative to perform other acts on behalf of the  
estate, you must file Form 2848, Power of Attorney and  
Declaration of Representative. Complete and attach Form  
2848 if you would like to authorize:  
If you are reporting any items on this return based on  
the provisions of a death tax treaty or protocol, attach a  
statement to this return indicating that the return position  
is treaty based. See Regulations section 301.6114-1 for  
How To Complete Form 706-NA  
Complete Form 706-NA in this order.  
1. Part I.  
2. Part III.  
Persons other than attorneys, accountants, or enrolled  
agents to represent the estate;  
3. Schedule A and B.  
4. Part II.  
More than one person to receive confidential  
information or represent the estate; or  
The estate tax is imposed on the decedent's gross  
estate in the United States, reduced by allowable  
deductions. Figure the gross estate in the United States  
on Schedule A. Reduce the Schedule A total by the  
allowable deductions to derive the taxable estate on  
Schedule B, and figure the tax due using Part II. Tax  
Someone to sign agreements, consents, waivers, or  
other documents for the estate.  
If you wish only to authorize someone to inspect or  
receive confidential tax information verbally and/or in  
writing, complete and attach Form 8821, Tax Information  
Authorization. Individuals authorized by Form 8821 are  
not authorized to:  
Speak on behalf of the estate;  
Instructions for Form 706-NA (Rev. 10-2022)  
Execute a request to allow disclosure of tax return or  
tax return information to another third party;  
Advocate your position with respect to federal tax  
Property in which the decedent either held a general  
power of appointment at the time of death, or used or  
released this power in certain ways before death.  
Certain annuities to surviving beneficiaries.  
Execute waivers, consents, closing agreements; or  
Represent you in any other manner before the IRS.  
For additional information concerning joint tenancies,  
tenancies by the entirety, annuities, life insurance,  
transfers during life, and powers of appointment, see the  
Instructions for Form 706.  
Question 6a. If you answer “Yes,” please attach a  
statement listing:  
The citizenship of the decedent's parents,  
Enter on Schedule A all of the assets that meet both of  
Whether the decedent became a U.S. citizen through  
a naturalization proceeding in the United States, and  
When the decedent lost U.S. citizenship or residency.  
the following tests.  
They are included in the entire gross estate.  
They are located in the United States.  
Question 6b. If you answered “Yes,” and the decedent  
lost U.S. citizenship or long-term resident status within 10  
years of death and prior to June 17, 2008, but you  
maintain that avoiding U.S. taxes was not a principal  
purpose for the decedent's loss of citizenship or  
residency, attach documents to sustain your position. See  
Definitions, earlier.  
Determining where assets are located. Unless a treaty  
provides otherwise (see Death Tax Treaties, earlier), use  
the following rules to determine whether assets are  
located in the United States.  
Real estate and tangible personal property. Real  
estate and tangible personal property are located in the  
United States if they are physically located there.  
Question 9. A general power of appointment is any  
power of appointment exercisable in favor of the  
decedent, the decedent's estate, the decedent's creditors,  
or the creditors of the decedent's estate, and includes the  
right of a beneficiary to appropriate or consume the  
principal of a trust. For a complete definition, see section  
Note. An exception is made for works of art that are  
owned by an NRNC decedent and are located within the  
United States, if on the date of death the works of art are:  
Imported solely for public exhibition,  
On loan to a nonprofit public gallery or museum, and  
On exhibition or en route to or from exhibition.  
Stock. Generally, no matter where stock certificates  
are physically located, stock of corporations organized in  
or under U.S. law is property located in the United States,  
and all other corporate stock is property located outside  
the United States.  
Stock in a regulated investment company (RIC).  
For an NRNC decedent who died after 2004 and before  
2012, a portion of stock in a RIC is treated as property  
located outside the United States in the proportion of the  
RIC's qualifying assets in relation to the total assets  
owned by the RIC at the end of the quarter immediately  
preceding the decedent's death.  
Schedule A. Gross Estate in the  
United States  
Before you complete Schedule A, you must determine  
what assets are included in the decedent's entire gross  
estate, wherever located. However, list on Schedule A  
only those assets located in the United States. Enter the  
total value of assets located outside the United States on  
line 2 of Schedule B.  
Entire gross estate. The entire gross estate is figured  
the same way for an NRNC decedent as for a U.S. citizen  
or resident. It consists of all property the decedent  
beneficially owned, wherever located, and includes the  
following property interests.  
Qualifying assets are assets that, if owned directly by  
the decedent, would have been:  
Bank deposits and amounts described in section  
Generally, the full value of property the decedent  
owned at the time of death as a joint tenant with right  
of survivorship (but if the surviving spouse is a U.S.  
citizen, then only half the value of property held by the  
decedent and surviving spouse either as joint tenants  
with right of survivorship or as tenants by the entirety).  
For exceptions, see the Instructions for Form 706,  
Schedule E.  
Portfolio debt obligations,  
Certain original issue discount obligations,  
Debt obligations of a U.S. corporation that are treated  
as giving rise to foreign source income, and  
Other property not within the United States.  
See section 2105(d) for details.  
Insurance proceeds. Proceeds of insurance policies  
on the decedent's life are property located outside the  
United States.  
Property the decedent and a surviving spouse owned  
as community property to the extent of the decedent's  
interest in the property under applicable state,  
possession, or foreign law.  
Debt obligations within United States. Debt  
obligations are generally property located in the United  
States if they are debts of a U.S. citizen or resident, a  
domestic partnership or corporation, a domestic estate or  
trust, the United States, a state or state's political  
subdivision, or the District of Columbia.  
A surviving spouse's dower or curtesy interest and all  
substitute interests created by statute.  
Proceeds of insurance on the decedent's life,  
generally including proceeds receivable by  
beneficiaries other than the estate.  
Several kinds of transfers the decedent made before  
Instructions for Form 706-NA (Rev. 10-2022)  
Debt obligations outside United States. The  
following debt obligations are generally treated as located  
outside the United States.  
Give the main exchange for listed stock. For unlisted  
stock, give the post office address of the main business  
office of the corporation, the state in which incorporated,  
and the incorporation date.  
Debt obligations (whether registered or unregistered)  
issued after July 18, 1984, if the interest on them  
would be eligible for tax exemption under section  
871(h)(1) had such interest been received by the  
decedent at the time of the decedent’s death.  
However, if the debt earns contingent interest, some  
or all of it may be considered property in the United  
States (section 2105(b)(3)).  
Bonds. In bond descriptions, include:  
The quantity and denomination,  
Obligor's name,  
Maturity date,  
Interest rate,  
Each date when interest is payable,  
Nine-digit CUSIP number, and  
Series number (if more than one issue).  
Certain short-term original issue discount debt  
Give the exchange where the bond is listed. If it is  
See section 2105(b)(4) for details.  
unlisted, give the corporation's main business office.  
CUSIP number. The CUSIP (Committee on Uniform  
Security Identification Procedures) 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  
certificate. If you do not have a stock certificate, the  
CUSIP number may be found on the broker's or  
custodian's statement or by contacting the company's  
transfer agent.  
Schedules E, G, or H. If you are required to file  
Schedule E, G, or H from Form 706, you do not need to  
enter the assets reported on those schedules on  
Schedule A of this Form 706-NA. Instead, attach the  
schedules to Form 706-NA, in column (b) enter “Total  
from Schedule __, Form 706,” and enter the total values  
from the attached schedules in either column (d) or (e).  
Deposits. The following deposits are treated as  
located outside the United States if they are not effectively  
connected with conducting a trade or business within the  
United States.  
A deposit with a U.S. bank or a U.S. banking branch of  
a foreign corporation.  
A deposit or withdrawable account with a savings and  
loan association chartered and supervised under  
federal or state law.  
An amount held by a U.S. insurance company under  
an agreement to pay interest.  
A deposit in a foreign branch of a U.S. bank.  
If an asset is included in the total gross estate because  
the decedent owned it at the time of death, apply the  
above location rules as of the date of the decedent's  
death. However, if an asset is included in the decedent's  
total gross estate under one of the transfer provisions  
(sections 2035, 2036, 2037, and 2038), it is treated as  
located in the United States if it fulfills these rules either at  
the time of the transfer or at the time of death.  
Property valuation date. Generally, property must be  
valued as of the date of death. Columns (c) and (d) do not  
apply in this case, and you may use the space to expand  
descriptions from column (b).  
For example, if an item of tangible personal property  
was physically located in the United States on the date of  
a section 2038 transfer but had been moved outside the  
United States at the time of the decedent's death, the item  
would be considered still located in the United States and  
should be listed on Schedule A.  
If the decedent was a U.S. expatriate subject to 877(b)  
at the time of death, the decedent is treated as owning a  
prorated share of the U.S. property held by a foreign  
corporation in which the decedent directly or indirectly  
owned at least 10% of the voting stock and, directly,  
indirectly, or constructively, owned more than 50% of the  
stock by vote or value (section 2107(b)).  
However, you may elect to use the alternate valuation  
date. To make this election, check the “Yes” box at the  
beginning of Schedule A. If you do so, the election applies  
to all property, and you will need to complete each column  
in Schedule A. Under this election, any property  
distributed, sold, exchanged, or otherwise disposed of  
within 6 months after the decedent's death is valued as of  
the date of the disposition. Any property not disposed of  
during that period is valued as of the date 6 months after  
the decedent's death.  
You may not elect alternate valuation unless the  
election will decrease both the value of the gross estate  
and the net estate tax due after application of all allowable  
Describe the property on Schedule A in enough detail  
to enable the IRS to identify it. To determine the fair  
market value of stocks and bonds, use the rules in the  
Instructions for Form 706, Schedule B—Stocks and  
Qualified Conservation Easement Exclusion  
Under section 2031(c), you may elect to exclude a portion  
of the value of land that is subject to a qualified  
conservation easement. You make the election by  
attaching Schedule U of Form 706 with all the required  
information. To elect the exclusion, you must include on  
Schedule A:  
Stocks. In descriptions of stock, include:  
The corporation's name;  
The number of shares;  
Whether common or preferred (if preferred, what  
1. The decedent's interest in the land that is subject to  
the exclusion, and  
The par value (when needed for identification);  
Nine-digit CUSIP number (defined later); and  
The quotation at which reported.  
2. Exclude the applicable value of the land (amount from  
line 20 of Schedule U) that is subject to the easement  
on Schedule A.  
Instructions for Form 706-NA (Rev. 10-2022)  
You must make the election on a timely filed Form  
706-NA, including extensions. For more information, see  
the Instructions for Form 706.  
Uncompensated losses that were incurred during  
settlement of the estate and that arose from theft or  
from casualties, such as fires, storms, or shipwrecks.  
You may deduct only that part of a debt or mortgage  
Canadian Small Estate Relief  
that was contracted in good faith and for full value in  
money or money's worth. You may deduct mortgages only  
to the extent of the full value of the mortgaged property  
included in the total gross estate on line 3. Do not deduct  
tax on income received after death or property taxes  
accrued after death. See Line 7, later, for details on  
deducting death taxes.  
If you are claiming a small estate exemption (worldwide  
estate of a Canadian resident decedent not more than  
$1.2 million) from tax on U.S. securities or certain other  
U.S. situs property under the 1995 Protocol to the  
Canadian income tax treaty, do not list the exempt assets  
on Schedule A.  
Instead, list those assets and their values in a  
On line 4, show the total of these deductible items. In  
statement attached to the return specifying that you are  
relying on the treaty. To determine initially whether the  
small estate exemption applies, however, you must  
include the exempt assets in the value of the entire gross  
estate, wherever located, on lines 2 and 3 of Schedule B.  
general, the total is limited to the amount on line 3.  
To document the line 4 amount, attach an itemized  
schedule. For each expense or claim, specify the nature  
and amount and give the creditor's name. Describe other  
deductions fully and identify any particular property to  
which they relate.  
United States–United Kingdom Treaty  
Line 6. Use line 6 to enter the following deductions.  
Charitable deduction. Unless a treaty allows  
If a decedent who was a U.K. national, but was neither  
domiciled in nor a national of the United States, has  
property that is subject to U.S. estate tax under the terms  
of the United States–United Kingdom Treaty, the treaty  
places a limit on the amount of U.S. estate tax owed on  
such property. The tax may not exceed the U.S. estate tax  
that could have been imposed on the decedent’s  
otherwise, you may take a charitable deduction only if the  
transfer was to a domestic entity or for use in the United  
States as described in the Instructions for Form 706.  
Attach Schedule O of Form 706. If you claim the  
deduction under a treaty, specify the applicable treaty and  
attach a computation of the deduction.  
Marital deduction. Unless a treaty allows otherwise,  
you may only take a marital deduction if the surviving  
spouse is a U.S. citizen or if the property passes to a  
qualified domestic trust (QDOT) described in section  
2056A and an election is made on Schedule M of Form  
706. See Regulations section 20.2056A-2(d) for additional  
QDOT requirements.  
worldwide assets had the decedent died domiciled in the  
United States. If the amount of tax on the property  
exceeds that limit, the lower amount may be reported as  
the tax due on the Form 706-NA. You must attach to the  
estate's Form 706-NA a statement showing the alternate  
computation and claiming the benefit of the treaty  
provision. See Paragraph 5 of Article 8 of the treaty.  
Schedule B. Taxable Estate  
Attach Schedule M of Form 706 and a statement  
For the line 5 deduction to be allowed, you must  
showing your computation of the marital deduction.  
complete lines 1 through 4 and document the  
See section 2518 for the rules governing disclaimers of  
interests in property.  
amounts you include on lines 2 and 4.  
Line 7. You may take a deduction on line 7 for death  
taxes (estate, inheritance, legacy, or succession taxes)  
you paid to any state or the District of Columbia on  
property listed in Schedule A. To calculate the deduction  
for state death taxes, use the formula below. Enter the  
result on line 7.  
Line 2. The amount on line 2 is the total value of the  
assets included in the entire gross estate that were  
located outside the United States.  
To document the line 2 amount, attach a certified copy  
of the foreign death tax return or, if none was filed, a  
certified copy of the estate inventory and the schedule of  
debts and charges that were filed with the foreign probate  
court or as part of the estate's administration proceedings.  
Supplement these documents with attachments if they do  
not set forth the entire gross estate outside the United  
States. If more proof is needed, you will be notified.  
Total value of assets in the gross estate  
subject to state death taxes  
Total state death  
taxes paid  
Gross estate located in the United States  
(line 1 of Schedule B)  
If you elected the alternate valuation date for property  
listed on Schedule A, use it also for the assets reported on  
line 2. Otherwise, value the amounts as of the date of  
Generally, you must claim this deduction within 4 years  
of filing the return. However, see section 2058(b) for  
exceptions and periods of limitations.  
For the deduction to be allowed, you must file a  
certificate signed by the appropriate official of the taxing  
state. The certificate should show:  
Line 4. You may deduct the following items whether or  
not they were incurred or paid in the United States.  
Funeral expenses.  
The total tax charged,  
Administration expenses.  
Claims against the estate.  
Unpaid mortgages and liens.  
Any discount allowed,  
Any penalties and interest imposed,  
The tax actually paid, and  
Each payment date.  
Instructions for Form 706-NA (Rev. 10-2022)  
If possible, attach the certificate to this return;  
otherwise, please file it as soon as possible.  
If you later recover any of the state tax for which you  
claim this deduction, you must notify the IRS at the  
following address within 30 days of receiving any refund  
of state taxes.  
Line 13. If you answered “Yes” to question 11 of Part III,  
you must complete and attach Schedules R and/or R-1  
from Form 706.  
For the purposes of Form 706-NA, the GST tax is  
imposed only on transfers of interests in property that are  
part of the gross estate in the United States. Therefore,  
when completing Schedules R and/or R-1, you should  
enter only transfers of interests in property that you listed  
on Schedule A of Form 706-NA. Otherwise, complete  
Schedules R and/or R-1 according to their instructions  
and enter the total GST tax from Schedule R on line 13.  
Department of the Treasury  
Internal Revenue Service Center  
Kansas City, MO 64999  
Part II. Tax Computation  
For details, see Regulations section 26.2663-2.  
Lines 4 and 5. To determine the tentative tax on the  
amount on line 2 (to be entered on line 5) and the tentative  
tax on the amount on line 3 (to be entered on line 4), use  
Table A—Unified Rate Schedule in the version of the  
Instructions for Form 706 that corresponds to the  
decedent's date of death.  
Line 7. Enter the unified credit. The unified credit is  
allowed for the smaller of the line 6 amount or the  
maximum unified credit. In general, the maximum unified  
credit is $13,000.  
Line 15. Attach an explanation if earlier payments were  
made to the IRS.  
Line 16. Pay the balance due within 9 months after the  
decedent's death unless an extension of time to pay was  
granted. Make the check or money order payable to  
“United States Treasury” for the face value in U.S. dollars.  
No checks of $100 million or more accepted. The  
IRS cannot accept a single check (including a cashier's  
check) for amounts of $100,000,000 ($100 million) or  
more. If you're sending $100 million or more by check,  
you'll need to spread the payments over two or more  
checks, with each check made out for an amount less  
than $100 million. The $100 million or more amount limit  
does not apply to other methods of payment (such as  
electronic payments).  
For a citizen of a U.S. possession (see section 2209),  
the maximum unified credit is the greater of:  
$13,000, or  
The product of $46,800 times a fraction.  
The numerator of the fraction is the part of the gross  
estate located in the United States (line 1 of Schedule B),  
and the denominator is the entire gross estate wherever  
located (line 3 of Schedule B).  
If there is more than one executor, all listed  
executors are responsible for the return. However,  
If the unified credit is affected by a treaty, see section  
it is sufficient for only one of the co-executors to  
sign the return.  
Note. At the time this form went to print, treaties with  
Australia, Canada, Finland, France, Germany, Greece,  
Italy, Japan, and Switzerland contained provisions to  
which section 2102(b)(3)(A) applies.  
Form 706-NA must be signed. The executor must verify  
and sign the declaration on page 1 under penalties of  
perjury. The executor may use Form 2848 to authorize  
another person to act for the executor before the IRS. See  
the instructions for the authorization in Part III. General  
Information, earlier, or the Instructions for Form 2848 and  
Circular 230, Regulations Governing Practice before the  
Internal Revenue Service, section 10.7(c)(1)(vii), for  
information on representing a person or entity located  
outside the United States.  
Third-party designee. If you want to allow the return  
preparer (listed on the bottom of page 1 of Form 706-NA)  
to discuss your Form 706-NA with the IRS, check the  
"Yes" box to the far right of your signature on page 1 of  
your return. If you check the "Yes" box, you are  
authorizing the IRS to call your return preparer to answer  
questions that may arise during the processing of your  
return. You are also authorizing the return preparer of your  
Form 706-NA to:  
Any amount previously allowed as a unified credit  
against the gift tax will reduce, dollar for dollar, the  
unified credit allowed the estate (section 2102(b)  
Line 9. Use line 9 to enter the following credits.  
Credit for federal gift taxes. See sections 2102 and  
2012. Attach computation of credit.  
Canadian marital credit. In addition to the unified  
credit, a nonrefundable marital credit may be allowed if  
the executor elects this treaty benefit and waives the  
benefit of any estate tax marital deduction allowable under  
U.S. law. The credit amount is generally limited to the  
lesser of:  
The unified credit allowed to the estate (before  
reduction for any gift tax unified credit), or  
The amount of estate tax that would otherwise be  
imposed by the United States on the transfer of  
qualifying property to the surviving spouse.  
Give the IRS any information that is missing from your  
Call the IRS for information about the processing of  
your return or the status of your payment(s);  
Receive copies of notices or transcripts related to your  
return, upon request; and  
See the 1995 Canadian income tax treaty protocol for  
details on computing the credit. Also, attach a  
Respond to certain IRS notices about math errors,  
offsets, and return preparation.  
computation of the credit, and on the dotted line to the left  
of the line 9 entry, enter “Canadian marital credit.”  
Instructions for Form 706-NA (Rev. 10-2022)  
You are not authorizing your return preparer to receive  
any refund check, to bind you to anything (including any  
additional tax liability), or otherwise represent you before  
the IRS. If you want to expand the authorization of your  
return preparer, see Pub. 947, Practice Before the IRS  
and Power of Attorney. The authorization will  
Paid Preparer Use Only area. See section 7701(a)(36)(B)  
for exceptions.  
In addition to signing and completing the required  
information, the paid preparer must give a copy of the  
completed return to the executor.  
automatically end 3 years from the date of filing Form  
706-NA. If you wish to revoke the authorization before it  
ends, see Pub. 947.  
Note. A paid preparer may sign original or amended  
returns by rubber stamp, mechanical device, or computer  
software program.  
Generally, anyone who is paid to prepare the return  
must sign the return in the space provided and fill in the  
Privacy Act and 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. Subtitle B and section 6109, and  
the regulations, require you to provide this information.  
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 administration of any Internal Revenue law. Generally, tax  
returns and return information are confidential as required by section 6103. However, section 6103 allows or requires the  
Internal Revenue Service to disclose information from this form in certain circumstances. For example, we may disclose  
information to the Department of Justice for civil or criminal litigation, and to cities, states, the District of Columbia, and  
U.S. commonwealths or possessions for use in administering their tax laws. We may also disclose this information to  
other countries under a tax treaty, to federal and state agencies to enforce federal nontax criminal laws, or to federal law  
enforcement and intelligence agencies to combat terrorism. Failure to provide this information, or providing false  
information, may subject you to penalties.  
The time needed to complete and file this form will vary depending on individual circumstances. The estimated  
average time is:  
Learning about the law or  
the form  
Preparing the form  
Copying, assembling, and  
sending the form to the IRS  
34 min.  
1 hr., 25 min.  
52 min.  
1 hr., 36 min.  
Comments and suggestions. We welcome your comments about these instructions and your suggestions for future  
editions. You can send us comments through IRS.gov/FormComments. Or, you can write to:  
Internal Revenue Service  
Tax Forms and Publications Division  
1111 Constitution Ave. NW, IR-6526  
Washington, DC 20224  
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, earlier.  
Instructions for Form 706-NA (Rev. 10-2022)