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Stock. Generally, no matter where

Deposits. The following deposits

nonresident alien decedent as for a

U.S. citizen or resident. It consists of all

stock certificates are physically located,

are treated as located outside the

property the decedent beneficially

stock of corporations organized in or

United States if they are not effectively

owned, wherever located, and includes

under U.S. law is properly located in

connected with conducting a trade or

the following property interests:

the United States, and all other

business within the United States:

•

Generally, the full value of property

corporate stock is property located

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

the decedent owned at the time of

outside the United States.

banking branch of a foreign corporation,

•

death as a joint tenant with right of

A deposit or withdrawable account

Stock in a Regulated Investment

survivorship (but if the surviving spouse

with a savings and loan association

Company (RIC). For a nonresident

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

chartered and supervised under federal

alien decedent who died after 2004, a

value of property held by the decedent

or state law,

portion of stock in a RIC is treated as

•

and surviving spouse either as joint

An amount held by a U.S. insurance

property located outside the United

tenants with right of survivorship or as

company under an agreement to pay

States in the proportion of the RIC’s

tenants by the entirety). For exceptions,

interest, and

qualifying assets in relation to the total

•

see the instructions for Form 706,

A deposit in a foreign branch of a

assets owned by the RIC at the end of

Schedule E;

U.S. bank.

the quarter immediately preceding the

•

Property the decedent and a

decedent’s death.

If an asset is included in the total

surviving spouse owned as community

gross estate because the decedent

Qualifying assets are assets that, if

property to the extent of the decedent’s

owned it at the time of death, apply the

owned directly by the decedent, would

interest in the property under applicable

above location rules as of the date of

have been:

state, possession, or foreign law;

the decedent’s death. However, if an

•

Bank deposits and amounts

•

A surviving spouse’s dower or

asset is included in the decedent’s total

described in section 871(i)(3),

curtesy interest and all substitute

gross estate under one of the transfer

•

Portfolio debt obligations,

interests created by statute;

provisions (sections 2035, 2036, 2037,

•

Certain original issue discount

•

Proceeds of insurance on the

and 2038), it is treated as located in the

obligations,

decedent’s life, generally including

United States if it fulfills these rules

•

Debt obligations of a U.S. corporation

proceeds receivable by beneficiaries

either at the time of the transfer or at

that are treated as giving rise to foreign

other than the estate;

the time of death.

source income, and

•

Several kinds of transfers the

•

For example, if an item of tangible

Other property not within the United

decedent made before death;

personal property was physically

States.

•

Property in which the decedent either

located in the United States on the date

See section 2105(d) for details.

held a general power of appointment at

of a section 2038 transfer but had been

Insurance proceeds. Proceeds of

the time of death, or used or released

moved outside the United States at the

insurance policies on the decedent’s life

this power in certain ways before

time of the decedent’s death, the item

are property located outside the United

death; and

would be considered still located in the

•

States.

Certain annuities to surviving

United States and should be listed on

beneficiaries.

Debt obligations within U.S. Debt

Schedule A.

obligations are generally property

For additional information

Describe the property on Schedule A

located in the United States if they are

concerning joint tenancies, tenancies

in enough detail to enable the IRS to

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

by the entirety, annuities, life insurance,

identify it. To determine the fair market

domestic partnership or corporation, a

transfers during life, and powers of

value of stocks and bonds, use the

domestic estate or trust, the United

appointment, see the Instructions for

rules in the Instructions for Form 706,

States, a state or state’s political

Form 706.

Schedule B — Stocks and Bonds.

subdivision, or the District of Columbia.

Enter on Schedule A all of the assets

Stocks. In descriptions of stock,

Debt obligations outside U.S. The

that meet both the following tests.

include:

•

following debt obligations are generally

They are included in the entire gross

•

The corporation’s name;

treated as located outside the United

estate and

•

The number of shares;

•

States:

They are located in the United

•

Whether common or preferred (if

•

Debt obligations (whether registered

States.

preferred, what issue);

or unregistered) issued after July 18,

•

Determining where assets are

The par value (when needed for

1984, if the interest on them would be

located. Unless a treaty provides

identification);

eligible for tax exemption under section

•

otherwise (see Death Tax Treaties,

Nine-digit CUSIP number (defined

871(h)(1) had such interest been

above), use the following rules to

below); and

received by the decedent at the time of

•

determine whether assets are located

The quotation at which reported.

his death. However, if the debt earns

in the United States.

Give the main exchange for listed

contingent interest, some or all of it

Real estate and tangible personal

stock. For unlisted stock, give the post

may be considered property in the

property. Real estate and tangible

office address of the main business

United States (section 2105(b)(3)).

•

personal property are located in the

office of the corporation, the state in

A debt obligation of a domestic

United States if they are physically

which incorporated, and the

corporation if the interest from it (had it

located there.

incorporation date.

been received at the time of death)

Note. An exception is made for works

Bonds. In bond descriptions,

would have been treated as income

of art that are owned by a nonresident

from outside the United States because

include:

•

alien and are located within the United

the corporation derived less than 20%

The quantity and denomination,

•

States, if on the date of death the works

of its gross income from sources in the

Obligor’s name,

•

of art are:

United States during its 3 tax years

Maturity date,

•

Imported solely for public exhibition,

before the decedent’s death (section

Interest rate,

•

On loan to a non-profit public gallery

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

Each date when interest is payable,

•

or museum, and

Certain short-term original issue

Nine-digit CUSIP number, and

•

On exhibition or en route to or from

discount debt obligations.

Series number (if more than one

exhibition.

See section 2105(b)(4) for details.

issue).

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Instructions Draft For Form 706-Na - United States Estate (And Generation-Skipping Transfer) Tax Return Estate Of Nonresident Not A Citizen Of The United States Page 4

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