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Specific Instructions

the total value of assets located outside

3. Proceeds of insurance policies on

the United States on line 2 of Schedule

the decedent’s life are property located

B.)

outside the United States.

Attachments

The “entire gross estate” is figured the

4. Debts are generally property

If the decedent died testate, attach a

same way for a nonresident alien

located in the United States if they are

certified copy of the will to Form

decedent as for a U.S. citizen or

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

706-NA. For closely held or inactive

resident. It consists of all property the

domestic partnership or corporation, a

corporate stock, attach the balance

decedent beneficially owned, wherever

domestic estate or trust, the United

sheets, particularly the one nearest the

located, and includes the following

States, a state or state’s political

valuation date, and statements of the

property interests:

subdivision, or the District of Columbia.

net earnings or operating results and

1. Generally, the full value of property

Debt obligations (whether registered or

dividends paid for each of the 5

the decedent owned at the time of

unregistered) are not considered located

preceding years. Attach any other

in the United States if interest on them

death as a joint tenant with right of

documents, such as appraisal lists,

survivorship (but if the surviving spouse

would be eligible for the exemption from

needed for explanation. Also attach

is a U.S. citizen, then only half the value

tax under section 871(h)(1) were such

copies of all available U.S. gift tax

of property held by the decedent and

interest received by the decedent at the

returns the decedent filed. Other

surviving spouse either as joint tenants

time of his death. However, for the

documents may be required as

with right of survivorship or as tenants

estates of decedents dying after 1993, if

explained in these instructions.

by the entirety). For exceptions, see the

the debt earns contingent interest, some

Attach an English translation to all

instructions on the reverse side of

or all of it may be considered property

documents in other languages.

Schedule E, Form 706.

located in the U.S. See section 2105(b)

as amended by section 13237(b) of the

2. Property the decedent and a

How To Complete Form

Revenue Reconciliation Act of 1993.

surviving spouse owned as community

706-NA

Also, a domestic corporation’s debt

property to the extent of the decedent’s

interest in the property under applicable

obligation is treated as located outside

First, enter the decedent’s name and the

state, possession, or foreign law.

the United States if the interest from it

other information called for in Part I.

(had it been received at the time of

3. A surviving spouse’s dower or

Then answer all of the questions in Part

death) would have been treated as

curtesy interest and all substitute

III.

income from outside the United States

interests created by statute.

The estate tax is imposed on the

because the corporation derived less

4. Proceeds of insurance on the

decedent’s gross estate in the United

than 20% of its gross income from

decedent’s life, generally including

States, reduced by allowable

sources in the United States during its 3

proceeds receivable by beneficiaries

deductions. Compute the gross estate in

tax years before the decedent’s death

other than the estate.

the United States on Schedule A.

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

5. Several kinds of transfers the

Reduce the Schedule A total by the

5. The following deposits are treated

decedent made before death.

allowable deductions to derive the

as located outside the United States if

taxable estate on Schedule B, and figure

6. Property in which the decedent

they are not effectively connected with

the tax due using the Tax Computation

either held a general power of

conducting a trade or business within

schedule (Part II).

appointment at the time of death, or

the United States:

used or released this power in certain

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

Part III—General Information

ways before death.

U.S. banking branch of a foreign

Question 6a.—If you answer “Yes,”

7. Certain annuities to surviving

corporation.

please attach a statement listing the

beneficiaries.

b. A deposit or withdrawable account

citizenship of the decedent’s parents;

For additional information concerning

with a savings and loan association

whether the decedent became a U.S.

joint tenancies, tenancies by the entirety,

chartered and supervised under Federal

citizen through a naturalization

annuities, life insurance, transfers during

or state law.

proceeding in the United States; and

life, and powers of appointment, see

c. An amount held by a U.S.

when the decedent lost U.S. citizenship.

Pub. 448.

insurance company under an agreement

Question 6b.—If you answer “Yes,” but

Enter on Schedule A all of the assets

to pay interest.

maintain that avoiding U.S. taxes was

that meet both the following tests:

d. A deposit in a foreign branch of a

not one of the main reasons for the

They are included in the “entire gross

U.S. bank.

decedent’s loss of citizenship, attach

estate” and

documents to sustain your position. See

If an asset is included in the total

They are located in the United States.

Definitions on page 1.

gross estate because the decedent

Unless a treaty provides otherwise

owned it at the time of death, apply

Question 9.—A general power of

(see Death Tax Treaties on page 1), use

these location rules as of the date of the

appointment means any power of

the following rules to determine whether

decedent’s death. However, if an asset

appointment exercisable in favor of the

assets are located in the United States:

is included in the decedent’s total gross

decedent, the decedent’s estate, the

estate under one of the transfer

decedent’s creditors, or the creditors of

1. Real estate and tangible personal

provisions (sections 2035, 2036, 2037,

the decedent’s estate, and includes the

property are located in the United States

and 2038), it is treated as located in the

right of a beneficiary to appropriate or

if they are physically located there. An

United States if it fulfills these rules

consume the principal of a trust. For a

exception is made for works of art

either at the time of the transfer or at

complete definition, see section 2041.

imported into the United States solely

the time of death. For example, if an

for public exhibition.

Schedule A

item of tangible personal property was

2. No matter where stock certificates

physically located in the United States

Before you complete Schedule A, you

are physically located, stock of

on the date of a section 2038 transfer

must determine what assets are

corporations organized in or under U.S.

but had been moved outside the United

included in the decedent’s entire gross

law is property located in the United

States at the time of the decedent’s

estate, wherever located. However, list

States, and all other corporate stock is

death, the item would be considered still

on Schedule A only those assets

property located outside the United

located in the United States and should

included in the entire gross estate that

States.

be listed on Schedule A.

are located in the United States. (Enter

Page 2

Instructions For Form 706-Na - United States Estate (And Generation-Skipping Transfer) Tax Return - Internal Revenue Service - 1993 Page 2

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