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corporate stock is property located

connected with conducting a trade or

If you are required to file Schedule

outside the United States.

business within the United States:

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

•

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

enter the assets reported on those

Stock in a Regulated Investment

banking branch of a foreign corporation,

schedules on Schedule A of this Form

Company (RIC). For a NA-decedent

•

A deposit or withdrawable account

706-NA. Instead, attach the schedules

who died after 2004, a portion of stock

with a savings and loan association

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

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

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.

the RIC at the end of the quarter

•

A deposit in a foreign branch of a

expatriate, the decedent is treated as

immediately preceding the decedent’s

U.S. bank.

owning a prorated share of the U.S.

death.

If an asset is included in the total

property held by a foreign corporation

Qualifying assets are assets that, if

gross estate because the decedent

in which he or she directly owned at

owned directly by the decedent, would

owned it at the time of death, apply the

least 10% of the voting stock and, with

have been:

above location rules as of the date of

related interests, controlled over 50% of

•

Bank deposits and amounts

the decedent’s death. However, if an

it (section 2107(b)).

described in section 871(i)(3),

•

asset is included in the decedent’s total

Property valuation date. Generally,

Portfolio debt obligations,

•

gross estate under one of the transfer

property must be valued as of the date

Certain original issue discount

provisions (sections 2035, 2036, 2037,

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

obligations,

•

and 2038), it is treated as located in the

apply in this case, and you may use the

Debt obligations of a U.S. corporation

United States if it fulfills these rules

space to expand descriptions from

that are treated as giving rise to foreign

either at the time of the transfer or at

column (b).

source income, and

the time of death.

•

Other property not within the

However, you may elect to use the

For example, if an item of tangible

United States.

alternate valuation date. To make this

personal property was physically

See section 2105(d) for details.

election, check the “Yes” box at the

located in the United States on the date

beginning of Schedule A. If you do so,

Insurance proceeds. Proceeds of

of a section 2038 transfer but had been

the election applies to all property, and

insurance policies on the decedent’s life

moved outside the United States at the

you will need to complete each column

are property located outside the United

time of the decedent’s death, the item

in Schedule A. Under this election, any

States.

would be considered still located in the

property distributed, sold, exchanged,

Debt obligations within U.S. Debt

United States and should be listed on

or otherwise disposed of within 6

obligations are generally property

Schedule A.

months after the decedent’s death is

located in the United States if they are

valued as of the date of the disposition.

Describe the property on Schedule A

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

Any property not disposed of during

in enough detail to enable the IRS to

domestic partnership or corporation, a

that period is valued as of the date 6

identify it. To determine the fair market

domestic estate or trust, the United

months after the decedent’s death.

value of stocks and bonds, use the

States, a state or state’s political

rules in the instructions for Schedule B

You may not elect alternate

subdivision, or the District of Columbia.

of Form 706.

valuation unless the election will

Debt obligations outside U.S. The

Stocks. In descriptions of stock,

decrease both the value of the gross

following debt obligations are generally

include:

estate and the net estate tax due after

•

treated as located outside the United

The corporation’s name;

application of all allowable credits.

•

States.

The number of shares;

•

Qualified Conservation

Debt obligations (whether registered

Whether common or preferred (if

or unregistered) issued after July 18,

Easement Exclusion

preferred, what issue);

•

1984, if the interest on them would be

The par value (when needed for

Under section 2031(c), you may elect to

eligible for tax exemption under section

identification);

exclude a portion of the value of land

•

871(h)(1) had such interest been

Nine-digit CUSIP number; and

that is subject to a qualified

•

received by the decedent at the time of

The quotation at which reported.

conservation easement. You make the

his death. However, if the debt earns

election by attaching Schedule U of

Give the main exchange for listed

contingent interest, some or all of it

Form 706 with all the required

stock. For unlisted stock, give the post

may be considered property in the

information. To elect the exclusion, you

office address of the main business

United States (section 2105(b)).

must include on Schedule A:

•

office of the corporation, the state in

A debt obligation of a domestic

1. The decedent’s interest in the

which incorporated, and the

corporation, if the interest from it (had it

land that is subject to the exclusion and

incorporation date.

been received at the time of death)

2. Exclude the applicable value of

would have been treated as income

Bonds. In bond descriptions,

the land (amount from line 20,

from outside the United States because

include:

•

Schedule U) that is subject to the

the corporation derived less than 20%

The quantity and denomination,

•

easement on Schedule A.

of its gross income from sources in the

Obligor’s name,

•

United States during its 3 tax years

Maturity date,

You must make the election on a

•

before the decedent’s death (section

Interest rate,

timely filed Form 706-NA, including

•

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

Each date when interest is payable,

•

extensions. For more information, see

•

Certain short-term original issue

Nine-digit CUSIP number, and

the Instructions for Form 706.

•

discount debt obligations. See section

Series number (if more than one

2105(b)(4) for details.

issue).

Canadian Small Estate Relief

Deposits. The following deposits

Give the exchange where the bond

If you are claiming a small estate

are treated as located outside the

is listed. If it is unlisted, give the

exemption (worldwide estate of a

United States, if they are not effectively

corporation’s main business office.

Canadian resident decedent not more

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Instructions For Form 706-Na - United States Estate (And Generation-Skipping Transfer) Tax Return - Internal Revenue Service - 2006 Page 3

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