Instructions For Rev-1647 Schedule M - Future Interest Compromise

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Instructions for Rev-1647 Schedule M
Future Interest Compromise
of tax payable on a future interest
General Information
when the rate of tax cannot be
Note. If a contingency
established with certainty.
makes it impossible on the
date of death to determine
Purpose of Schedule
Note. This schedule is
the rate of tax which will apply when
Use Rev-1647 Schedule M is report
applicable only if a
a future interest vests and a
all future interests where the rate of
contingency makes it
compromise determination is not
tax which will be applicable when the
impossible on the date of death of a
requested by the taxpayer, the
future interest vests in possession
decedent to determine the rate of tax
Department will assess tax at the
and enjoyment cannot be established
which will apply when a future
highest rates which would apply at all
with certainty.
interest vests in possession and
points of uncertainty in the chain of
enjoyment. A compromise request is
distribution.
not necessary if all potential
Form Instructions
beneficiaries are taxable at the same
rate, and the only uncertainty is the
Note. To request a
Estate of
identity of the ultimate beneficiary of
compromise determination,
a future interest.
the person responsible for
Enter the complete name of the
filing the return must fill in oval 5
estate as shown on the REV-1500,
Schedule M must accompany the
“Future Interest Compromise” of the
Pennsylvania Inheritance Tax Return.
return if a compromise determination
REV-1500.
is requested. All information having a
File Number
direct or indirect effect on the
Enter the file number of the estate
compromise portion of the estate
assigned by the Register of Wills as
should be presented with the return.
The Inheritance Tax Division, upon
shown on the REV-1500,
The estate is encouraged to
written request, will provide the
Pennsylvania Inheritance Tax Return.
provide any information that is
probability factor in the case of an
deemed to have an impact on the
actual decedent prior to the filing of
possible future benefit to the
the tax return. Inquiries should be
General Instructions
respective beneficiaries so that the
addressed to:
Department may make informed
judgments. This may include, but
PA DEPARTMENT OF REVENUE
would not be limited to: the health
Important. This Schedule
BUREAU OF INDIVIDUAL TAXES
and lifestyle of the respective
is appropriate only for
INHERITANCE TAX DIVISION
beneficiaries, individual wealth of the
estates of decedent dying
PO BOX 280601
beneficiary, average expenses,
after December 12, 1982.
HARRISBURG, PA 17128-0601
expected income, etc. The estate’s
compromise offer should be
I Beneficiaries
The request for a probability factor
supported by as much factual data
must identify the estate, date of
List the name, relationship, date of
and explanatory information as
death, bureau file number, and must
birth and age to nearest birthday of
possible.
be accompanied by a copy of any
each beneficiary indicated in the
The Department of Revenue will
relevant instrument.
instrument which created the future
review the information presented to
interest compromise.
determine if a compromise
determination is appropriate and to
II Right of Withdrawal
When the “Notice of Inheritance
evaluate the suggested compromise
Tax Appraisement, Allowance or
For decedents dying on or after July
tax amount submitted by the
Disallowance of Deductions and
1, 1994, if a surviving spouse
taxpayer. The Department’s review
Assessment of Tax” is received, the
exercised or intends to exercise a
may be based on actuarial
taxpayer may, within 60 days of the
right of withdrawal within nine
computation, subjective analysis, or
date the assessment is received,
months of the decedent’s death,
a combination of both. If the facts
exercise the statutory right of appeal
check the appropriate block.
presented on Schedule M do not
provided in 72 P.S. § 9186(b). Any
reveal any extraordinary
liability not paid in full or under
III Explanation of
circumstances, the determination of
appeal will be referred for collection
Compromise Offer
the Department will be made by an
at the expiration of the appeal period
Section 9116(e) of the Inheritance
actuarial formula without any
or nine months after the date of
and Estate Tax Act of 1991 [72 P.S.
subjective review.
death, whichever is later.
§ 9116(e)] effective October 3, 1991
authorizes the Department of
Revenue to compromise the amount

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