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They are included in the entire gross

States, a state or state’s political

rules in the instructions for Schedule B

estate and

subdivision, or the District of Columbia.

of Form 706.

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They are located in the United

Debt obligations outside U.S.

Stocks. In descriptions of stock,

States. (See Determining where assets

The following debt obligations are

include:

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are located below.)

generally treated as located outside the

The corporation’s name;

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United States.

The number of shares;

Determining where assets are

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located. Unless a treaty provides

Debt obligations (whether registered

Whether common or preferred (if

otherwise (see Death Tax Treaties on

or unregistered) issued after July 18,

preferred, what issue);

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page 2), use the following rules to

1984, if the interest on them would be

The par value (when needed for

determine whether assets are located

eligible for tax exemption under section

identification);

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871(h)(1) had such interest been

in the United States.

Nine-digit CUSIP number; and

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received by the decedent at the time of

The quotation at which reported.

Real estate and tangible personal

his death. However, if the debt earns

property. Real estate and tangible

Give the main exchange for listed

contingent interest, some or all of it

personal property are located in the

stock. For unlisted stock, give the post

may be considered property in the

United States, if they are physically

office address of the main business

United States (section 2105(b)).

located there.

office of the corporation, the state in

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A debt obligation of a domestic

which incorporated, and the

Note. An exception is made for works

corporation, if the interest from it (had it

incorporation date.

of art, which are owned by a

been received at the time of death)

nonresident alien (NA) and are located

Bonds. In bond descriptions,

would have been treated as income

within the United States, if on the date

include:

from outside the United States because

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of death (of the NA-owner), the works

The quantity and denomination,

the corporation derived less than 20%

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of art are:

Obligor’s name,

of its gross income from sources in the

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Imported solely for public exhibition,

Maturity date,

United States during its 3 tax years

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On loan to a non-profit public gallery

Interest rate,

before the decedent’s death (section

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or museum, and

Each date when interest is payable,

861(a)(1)(A)).

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On exhibition or en route to or from

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Nine-digit CUSIP number, and

Certain short-term original issue

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exhibition.

Series number (if more than one

discount debt obligations. See section

issue).

Stock. Generally, no matter where

2105(b)(4) for details.

Give the exchange where the bond

stock certificates are physically located,

Deposits. The following deposits

is listed. If it is unlisted, give the

stock of corporations organized in or

are treated as located outside the

corporation’s main business office.

under U.S. law is properly located in

United States, if they are not effectively

the United States, and all other

connected with conducting a trade or

If you are required to file Schedule

corporate stock is property located

business within the United States:

E, G, or H from Form 706, you need not

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outside the United States.

A deposit with a U.S. bank or a U.S.

enter the assets reported on those

banking branch of a foreign corporation,

schedules on Schedule A of this Form

Stock in a Regulated Investment

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A deposit or withdrawable account

706-NA. Instead, attach the schedules

Company (RIC). For a NA-decedent

with a savings and loan association

to Form 706-NA, in column (b) enter

who died after 2004, a portion of stock

in a regulated investment company

chartered and supervised under federal

“Total from Schedule _ _ _ _ _, Form

(RIC) is treated as property located

or state law,

706,” and enter the total values from

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outside the United States in the

An amount held by a U.S. insurance

the attached schedules in either column

proportion of the RIC’s qualifying assets

company under an agreement to pay

(d) or (e).

in relation to the total assets owned by

interest, and

If the decedent was a U.S.

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A deposit in a foreign branch of a

the RIC at the end of the quarter

expatriate, the decedent is treated as

U.S. bank.

immediately preceding the decedent’s

owning a prorated share of the U.S.

death.

If an asset is included in the total

property held by a foreign corporation

gross estate because the decedent

in which he or she directly owned at

Qualifying assets are assets that, if

owned it at the time of death, apply the

least 10% of the voting stock and, with

owned directly by the decedent, would

above location rules as of the date of

related interests, controlled over 50% of

have been:

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the decedent’s death. However, if an

it (section 2107(b)).

Bank deposits and amounts

described in section 871(i)(3),

asset is included in the decedent’s total

Property valuation date. Generally,

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gross estate under one of the transfer

Portfolio debt obligations,

property must be valued as of the date

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provisions (sections 2035, 2036, 2037,

Certain original issue discount

of death. Columns (c) and (d) do not

and 2038), it is treated as located in the

obligations,

apply in this case, and you may use the

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United States if it fulfills these rules

Debt obligations of a U.S. corporation

space to expand descriptions from

either at the time of the transfer or at

that are treated as giving rise to foreign

column (b).

the time of death.

source income, and

However, you may elect to use the

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Other property not within the

For example, if an item of tangible

alternate valuation date. To make this

United States.

personal property was physically

election, check the “Yes” box at the

See section 2105(d) for details.

located in the United States on the date

beginning of Schedule A. If you do so,

of a section 2038 transfer but had been

Insurance proceeds. Proceeds of

the election applies to all property, and

moved outside the United States at the

insurance policies on the decedent’s life

you will need to complete each column

time of the decedent’s death, the item

are property located outside the United

in Schedule A. Under this election, any

would be considered still located in the

States.

property distributed, sold, exchanged,

United States and should be listed on

Debt obligations within U.S. Debt

or otherwise disposed of within 6

Schedule A.

obligations are generally property

months after the decedent’s death is

located in the United States if they are

Describe the property on Schedule A

valued as of the date of the disposition.

debts of a U.S. citizen or resident, a

in enough detail to enable the IRS to

Any property not disposed of during

domestic partnership or corporation, a

identify it. To determine the fair market

that period is valued as of the date 6

domestic estate or trust, the United

value of stocks and bonds, use the

months after the decedent’s death.

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Instructions For Form 706-Na - United States Estate (And Generation-Skipping Transfer) Tax Return - 2007 Page 3

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