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and 2038), it is treated as located in the

otherwise disposed of within 6 months

and the denominator is the amount on

United States if it fulfills these rules

after the decedent’s death is valued as

line 3. Enter the result on line 5.

either at the time of the transfer or at

of the date of the disposition. Any

Line 6.—Char itable deduction.—Unless

property not disposed of during that

the time of death. For example, if an

a treaty allows otherwise, you may take

item of tangible personal property was

period is valued as of the date 6 months

a charitable deduction only if the

physically located in the United States

after the decedent’s death.

transfer was to a domestic entity or for

on the date of a section 2038 transfer

You may not elect alternate valuation

use in the United States as described in

but had been moved outside the United

unless the election will decrease both

Pub. 448. Attach Schedule O of Form

States at the time of the decedent’s

the value of the gross estate and the net

706. If you claim the deduction under a

death, the item would be considered still

estate tax due after application of all

treaty, specify the applicable treaty and

located in the United States and should

allowable credits.

attach a computation of the deduction.

be listed on Schedule A.

Mar ital deduction.—Unless a treaty

Schedule B

Describe the property on Schedule A

allows otherwise, you may only take a

in enough detail to enable the IRS to

marital deduction if the surviving spouse

For the line 5 deduction to be allowed,

identify it. To determine the fair market

is a U.S. citizen or if the property passes

you must complete lines 1–4 and

value of stocks and bonds, use the rules

to a qualified domestic trust (QDOT)

document the amounts you include on

in the instructions for Schedule B of

described in section 2056A and an

lines 2 and 4.

Form 706.

election is made on Schedule M of Form

To document the line 2 amount, attach a

In descriptions of stock include the

706.

certified copy of the foreign death tax

corporation’s name; the number of

If you claim a marital deduction,

return; or if none was filed, a certified

shares; whether common or preferred (if

include the deduction on line 6. Attach

copy of the estate inventory and the

preferred, what issue); the par value

Schedule M of Form 706, and a

schedule of debts and charges that were

(when needed for identification); CUSIP

statement showing your computation of

filed with the foreign probate court or as

number if available; and the quotation at

the marital deduction.

part of the estate’s administration

which reported. Give the main exchange

See section 2518 for the rules

proceedings. If more proof is needed,

for listed stock; for unlisted stock, give

governing disclaimers of interests in

you will be notified.

the post office address of the main

property.

To support the line 4 amount, attach

business office of the corporation, the

an itemized schedule. For each expense

state in which incorporated, and the

Part II.—Tax Computation

or claim, specify the nature and amount

incorporation date.

Line 4.—If line 3 of Part II is $10 million

and give the creditor’s name. Describe

In bond descriptions include the

or less, use the amount on line 3 to find

other deductions fully and identify any

quantity and denomination; obligor’s

the tax in the Tax Table below. Enter the

particular property to which they relate.

name; maturity date; interest rate; each

tax on line 4, Part II.

Line 2.—The amount on line 2 is the

date when interest is payable; CUSIP

If line 3 of Part II exceeds $10 million,

total value of the assets included in the

number if available; and series number

use the worksheet on page 4 to figure

entire gross estate that were located

(if more than one issue). Give the

the amount to enter on line 4, Part II.

outside the United States. If you claim

exchange where the bond is listed; if it

deductions on line 5 of Schedule B, you

Line 5.—If line 2 of Part II is $10 million

is unlisted, give the corporation’s main

must also document the amount you

or less, use the amount on line 2 to find

business office.

enter on line 2. See the first paragraph

the tax in the Tax Table below. Enter the

If you are required to file Schedule E,

under Schedule B, above. If you elected

tax on line 5, Part II.

G, or H from Form 706, you need not

the alternate valuation date for property

If line 2 of Part II exceeds $10 million,

enter the assets reported on those

listed on Schedule A, use it also for the

use the worksheet on page 4 to figure

schedules on Schedule A of this Form

assets reported on line 2. Otherwise,

the amount to enter on line 5, Part II.

706-NA. Instead, attach the schedules

value the amounts as of the date of

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

Column A

Column B

Column C

Column D

death.

“Total from Schedule - - - - , Form 706,”

Rate of tax

Line 4.—You may deduct the following

and enter the total values from the

Taxable

Tax on

on excess

amount

amount in

over

items whether or not they were incurred

attached schedules in either column (d)

over

not over

column A

amount in

or paid in the United States: funeral

or (e).

column A

expenses; administration expenses;

If the decedent was a U.S. expatriate,

(Percent)

claims against the estate; unpaid

the decedent is treated as owning a

$10,000

mortgages and other liens; and

prorated share of the U.S. property held

$10,000

20,000

$1,800

uncompensated losses that were

20,000

40,000

3,800

by a foreign corporation in which he or

incurred during settlement of the estate

40,000

60,000

8,200

she directly owned at least 10% of the

and that arose from theft or from

60,000

80,000

13,000

voting stock and, with related interests,

casualties such as fires, storms, or

80,000

100,000

18,200

controlled over 50% of it (section

shipwrecks. You may deduct only that

100,000

150,000

23,800

2107(b)).

150,000

250,000

38,800

part of a debt or mortgage that was

Property valuation date.—Generally,

250,000

500,000

70,800

contracted in good faith and for full

500,000

750,000

155,800

property must be valued as of the date

value in money or money’s worth. You

750,000

1,000,000

248,300

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

may deduct mortgages only if you

1,000,000

1,250,000

345,800

apply in this case, and you may use the

included the full value of the mortgaged

1,250,000

1,500,000

448,300

space to expand descriptions from

property in the total gross estate on line

1,500,000

2,000,000

555,800

column (b).

3. Do not deduct death taxes, tax on

2,000,000

2,500,000

780,800

However, you may elect to use the

income received after death, or property

2,500,000

- - - - - -

1,025,800

alternate valuation date. To make this

taxes accrued after death.

Line 7.—Enter the unified credit. The

election, check the “Yes” box at the

On line 4, show the total of these

unified credit is allowed for the smaller

beginning of Schedule A. If you do so,

deductible items. In general, the total is

of the line 6 amount or the maximum

the election applies to all property, and

limited to the amount on line 3.

unified credit. In general, the maximum

you will need to complete each column

Line 5.—To find your actual deduction,

unified credit is $13,000. For a citizen of

in Schedule A. Under this election, any

multiply the line 4 amount by a fraction.

a U.S. possession (section 2209) the

property distributed, sold, exchanged, or

The numerator is the amount on line 1,

maximum unified credit is the greater of:

Page 3

Instructions For Form 706-Na - United States Estate (And Generation-Skipping Transfer) Tax Return - 1993 Page 3

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