Instructions For Form 706 - United States Estate (And Generation-Skipping Transfer) Tax Return - 2011 Page 37

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allocations are deemed to have been
that may later have taxable
WORKSHEET (inclusion ratio):
made in the following order:
terminations or distributions under
1 Total estate and gift tax value of
section 2612 even if the form is not
1. To inter vivos direct skips and
all of the property interests that
required to be filed to report estate or
2. Beginning with transfers made
passed to the trust . . . . . . . . . .
GST tax.
after December 31, 2000, to lifetime
2 Estate taxes, state death taxes,
Line 9, column C. Enter the GST
transfers to certain trusts, by the
and other charges actually
decedent, that constituted indirect skips
exemption included on lines 2 through
recovered from the trust . . . . . .
6 of Part 1 of Schedule R, and
that were subject to the gift tax.
3 GST taxes imposed on direct
discussed above, that was allocated to
skips to skip persons other than
For more information, see section
the trust.
this trust and borne by the
2632.
property transferred to this trust
Line 9, column D. Allocate the
4 GST taxes actually recovered
Line 3. Make an entry on this line if
amount on line 8 of Part 1 of Schedule
from this trust (from Schedule R,
you are filing Form(s) 709 for the
R in line 9, column D. This amount may
Part 2, line 8 or Schedule R-1,
decedent and wish to allocate any
be allocated to transfers into trusts that
line 6) . . . . . . . . . . . . . . . . . . .
exemption.
are not otherwise reported on Form
5 Add lines 2 through 4 . . . . . . . .
Lines 4, 5, and 6. These lines
706. For example, the line 8 amount
6 Subtract line 5 from line 1 . . . . .
may be allocated to an inter vivos trust
represent your allocation of the GST
7 Add columns C and D of line 9 . .
exemption to direct skips made by
established by the decedent during his
8 Divide line 7 by line 6 . . . . . . . .
reason of the decedent’s death.
or her lifetime and not included in the
9 Trust’s inclusion ratio. Subtract
Complete Parts 2 and 3 and Schedule
gross estate. This allocation is made by
line 8 from 1.000 . . . . . . . . . . .
R-1 before completing these lines.
identifying the trust on line 9 and
making an allocation to it using column
Line 9. Line 9 is used to allocate the
Line 10. Special-use allocation. For
D. If the trust is not included in the
remaining unused GST exemption
skip persons who receive an interest in
gross estate, value the trust as of the
(from line 8) and to help you compute
section 2032A special-use property,
date of death. You should inform the
the trust’s inclusion ratio. Line 9 is a
you may allocate more GST exemption
trustee of each trust listed on line 9 of
Notice of Allocation for allocating the
than the direct skip amount to reduce
the total GST exemption you allocated
GST exemption to trusts as to which
the additional GST tax that would be
to the trust. The trustee will need this
the decedent is the transferor and from
due when the interest is later disposed
information to compute the GST tax on
which a generation-skipping transfer
of or qualified use ceases. See
future distributions and terminations.
could occur after the decedent’s death.
Schedule A-1, above, for more details
Line 9, column E. Trust’s
If line 9 is not completed, the
about this additional GST tax.
inclusion ratio. The trustee must
deemed allocation at death rules will
know the trust’s inclusion ratio to figure
Enter on line 10 the total additional
apply to allocate the decedent’s
the trust’s GST tax for future
GST exemption available to allocate to
remaining unused GST exemption, first
distributions and terminations. You are
all skip persons who received any
to property that is the subject of a direct
not required to inform the trustee of the
interest in section 2032A property.
skip occurring at the decedent’s death,
inclusion ratio and may not have
Attach a special-use allocation
and then to trusts as to which the
enough information to compute it.
schedule listing each such skip person
decedent is the transferor. If you wish
Therefore, you are not required to
and the amount of the GST exemption
to avoid the application of the deemed
make an entry in column E. However,
allocated to that person.
allocation rules, you should enter on
column E and the worksheet below are
line 9 every trust (except certain trusts
If you do not allocate the GST
provided to assist you in computing the
entered on Schedule R-1, as described
exemption, it will be automatically
inclusion ratio for the trustee if you wish
below) to which you wish to allocate
allocated under the deemed allocation
to do so.
any part of the decedent’s GST
at death rules. To the extent any
exemption. Unless you enter a trust on
You should inform the trustee of the
amount is not so allocated, it will be
amount of the GST exemption you
line 9, the unused GST exemption will
automatically allocated to the earliest
be allocated to it under the deemed
allocated to the trust. Line 9, columns C
disposition or cessation that is subject
allocation rules.
and D may be used to compute this
to the GST tax. Under certain
amount for each trust.
If a trust is entered on Schedule R-1,
circumstances, post-death events may
the amount you entered on line 4 of
Note. This worksheet will compute an
cause the decedent to be treated as a
Schedule R-1 serves as a Notice of
accurate inclusion ratio only if the
transferor for purposes of Chapter 13.
Allocation and you need not enter the
decedent was the only settlor of the
Line 10 may be used to set aside an
trust on line 9 unless you wish to
trust. You should use a separate
exemption amount for such an event.
allocate more than the Schedule R-1,
worksheet for each trust (or separate
You must attach a schedule listing each
line 4 amount to the trust. However,
share of a trust that is treated as a
such event and the amount of
you must enter the trust on line 9 if you
separate trust).
exemption allocated to that event.
wish to allocate any of the unused GST
exemption amount to it. Such an
Parts 2 and 3
additional allocation would not ordinarily
Use Part 2 to compute the GST tax on
be appropriate in the case of a trust
transfers in which the property interests
entered on Schedule R-1 when the
transferred are to bear the GST tax on
trust property passes outright (rather
the transfers. Use Part 3 to report the
than to another trust) at the decedent’s
GST tax on transfers in which the
death. However, where section 2032A
property interests transferred do not
property is involved, it may be
bear the GST tax on the transfers.
appropriate to allocate additional
exemption amounts to the property.
Section 2603(b) requires that unless
See the instructions for line 10 below.
the governing instrument provides
To avoid application of the
otherwise, the GST tax is to be charged
!
deemed allocation rules, Form
to the property constituting the transfer.
706 and Schedule R should be
Therefore, you will usually enter all of
CAUTION
filed to allocate the exemption to trusts
the direct skips on Part 2.
-37-
Part Instructions

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