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                                                                                                       Department of the Treasury
                                                                                                       Internal Revenue Service
Instructions for Form 706-NA

(Rev. September 2021)
United States Estate (and Generation-Skipping Transfer) Tax Return
Estate of nonresident not a citizen of the United States

Section references are to the Internal Revenue basis (estate tax value) of the asset      administrator, or administratrix of the 
Code unless otherwise noted.                   when it was received by the beneficiary.   deceased person's estate. If no 
                                               To satisfy the consistent basis reporting  executor is appointed, qualified, and 
                                               requirements, the estate must file Form    acting in the United States, every 
Future Developments                            8971, Information Regarding                person in actual or constructive 
                                               Beneficiaries Acquiring Property From a    possession of any of the decedent's 
For the latest information about               Decedent. See Form 8971 and its            property must file a return. If more than 
developments related to Form 706-NA            instructions.                              one person must file, it is preferable that 
and its instructions, such as legislation                                                 they join in filing one complete return. 
enacted after they were published, go to       Closing letter procedure.  Estate tax 
                                                                                          Otherwise, each must file as complete a 
IRS.gov/Form706NA.                             closing letters will not be issued unless 
                                                                                          return as possible, including a full 
                                               requested by the executor of the estate 
                                                                                          description of the property and each 
                                               or other authorized individual. To allow 
                                                                                          person's name who holds an interest in 
General Instructions                           time for processing, please wait at least 
                                                                                          it.
                                               9 months after filing Form 706-NA to 
Purpose of Form                                request an estate tax closing letter.         Executors must provide 
                                                                                          documentation proving their status. 
Form 706-NA is used to compute estate          Instead of an estate tax closing letter, 
                                                                                          Documentation will vary but may include 
and generation-skipping transfer (GST)         the executor of the estate may request 
                                                                                          a certified copy of the will or a court 
tax liability for nonresident alien            an account transcript, which reflects 
                                                                                          order designating the executor(s). A 
decedents. The estate tax is imposed           transactions including the acceptance of 
                                                                                          statement by the executor(s) attesting to 
on the transfer of the decedent's taxable      Form 706-NA and the completion of an 
                                                                                          their status is insufficient.
estate rather than on the receipt of any       examination. Account transcripts are 
part of it.                                    available online to registered tax         U.S. expatriate. Special estate tax 
      For information about transfer           professionals using the Transcript         rules may apply to decedents who 
TIP   certificates for U.S. assets, write      Delivery System (TDS) or to authorized     expatriated from the United States prior 
      to the following address.                representatives making requests using      to death. For these purposes, both U.S. 
                                               Form 4506-T. Specific instructions are     citizens who relinquished their 
Internal Revenue Service                       available for requesting online            citizenship and long-term residents, as 
Attn: E&G, Stop 824G                           transcripts using the TDS or hardcopy      defined in section 877(e), who have 
7940 Kentucky Drive                            transcripts using Form 4506-T. For         surrendered their green card or taken a 
Florence, KY 41042-2915                        questions about estate tax closing letter  position under a tax treaty that they are 
                                               requests, go to Frequently Asked           solely a resident of the other country, 
                                               Questions on Estate Taxes.                 are treated as expatriates.
Note. In order to complete this return,                                                      For decedents who expatriated prior 
you must obtain Form 706, United               Definitions                                to June 17, 2008, and were still subject 
States Estate (and Generation-Skipping         The following definitions apply in these   to the 10-year alternative tax regime of 
Transfer) Tax Return, and its                  instructions.                              section 877(b) on the date of death, the 
instructions. You must attach schedules                                                   rules in section 2107 apply to determine 
from Form 706 if you intend to claim a         United States.  The United States 
marital deduction, a charitable                means the 50 states and the District of    the value of the decedent’s U.S. taxable 
deduction, a qualified conservation            Columbia.                                  estate. For decedents who expatriated 
                                                                                          on or after June 17, 2008, and were 
easement exclusion, or a credit for tax        Nonresident alien decedent.     A          “covered expatriates” on the date of 
on prior transfers, or if you answer “Yes”     nonresident alien decedent is a            death, as defined in section 877A(g)(1), 
to question 5, 7, 8, 9a, 9b, or 11 in Part     decedent who is neither domiciled in nor   the rules in section 2107 do not apply, 
III. General Information. You will need        a citizen of the United States at the time but the rules of section 2801 may apply. 
the Instructions for Form 706 to explain       of death. For purposes of this form, a     So decedents who expatriated on or 
how to value stocks and bonds. Make            citizen of a U.S. possession is not a      after June 17, 2008, are generally 
sure that you use the version of Form          U.S. citizen.                              subject to U.S. estate tax as all other 
706 that corresponds to the date of the                                                   nonresident alien decedents, and the 
decedent's death.                              Long-term U.S. resident. A long-term 
                                               U.S. resident is an alien who has been a   references to “U.S. expatriate” in these 
Consistent basis reporting.     Estates        lawful permanent resident of the United    instructions refer only to decedents who 
are required to report to the IRS and the      States (green card holder) in at least 8   expatriated prior to June 17, 2008. See 
recipient the estate tax value of each         of the last 15 tax years ending with the   the instructions for Question 6a and 
asset included in the gross estate within      tax year in which U.S. residency is        Question 6b, later. Also, see effective 
30 days of filing Form 706-NA, or earlier      terminated.                                dates, later, for more information.
if the return is filed late. The basis of                                                    Expatriation after June 3, 2004, 
certain assets when sold or otherwise          Executor. An executor is the personal 
disposed of must be consistent with the        representative, executor, executrix,       but before June 17, 2008.    A decedent 

Aug 31, 2021                                               Cat. No. 63118N



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would have been subject to the 10-year    the “Form 706-NA” box in Part II of Form      return. Estate tax return preparers who 
alternative tax regime of section 877(b)  4768.                                         prepare any return or claim for refund 
if the individual met one of three tests                                                that reflects an understatement of tax 
                                          Private delivery services (PDSs). 
set out under section 877(a) relating to:                                               liability due to willful or reckless conduct 
                                          You can use certain PDSs designated 
                                                                                        are subject to a penalty of $5,000 or 
1. Average annual net income tax          by the IRS to meet the "timely mailing as 
                                                                                        75% of the income earned (or income to 
liability,                                timely filing/paying" rule for tax returns 
                                                                                        be earned), whichever is greater, for the 
                                          and payments. Go to IRS.gov/PDS for 
                                                                                        preparation of each such return. See 
2. Net worth, and                         the current list of designated services.
                                                                                        section 6694(a) and 6694(b), the related 
3. Certification of tax compliance.       The PDS can tell you how to get               regulations, and Ann. 2009-15, 2009-11 
See sections 877 and 2107 and Form        written proof of the mailing date.            I.R.B. 687, available at Announcement 
8854, Initial and Annual Expatriation     For the IRS mailing address to use if         2009-15, for more information.
Statement, as they existed in the         you're using a PDS, go to IRS.gov/
relevant tax year for additional          PDSStreetAddresses.                           Death Tax Treaties
information.                                       PDSs can’t deliver items to P.O.     Death tax treaties are in effect with the 
                                                                                        following countries.
Expatriation on or after February         !        boxes. You must use the U.S. 
6, 1995, through June 3, 2004.      A     CAUTION  Postal Service to mail any item 
decedent would have been presumed to      to an IRS P.O. box address.                   Australia        Ireland 
be subject to the 10-year alternative tax                                               Austria          Italy 
                                                                                        Canada*          Japan 
regime of section 877(b) if the           Where To File                                 Denmark          Netherlands 
individual's average annual net income    File Form 706-NA at the following             Finland          South Africa
tax liability or net worth exceeded       address.                                      France           Switzerland
certain limits, absent a private letter 
                                                                                        Germany          United Kingdom
ruling reversing the presumption. See     Department of the Treasury                    Greece
sections 877 and 2107 and Form 8854       Internal Revenue Service Center
as they existed in the relevant tax year  Kansas City, MO 64999                          *Article XXIX B of the United States-Canada 
for additional information.                                                             Income Tax Treaty
                                          If using a PDS, use this address.
Who Must File
The executor must file Form 706-NA if     Internal Revenue Submission                   If you are reporting any items on this 
the date of death value of the            Processing Center                             return based on the provisions of a 
decedent’s U.S.-situated assets,          333 W. Pershing                               death tax treaty or protocol, attach a 
together with the gift tax specific       Kansas City, MO 64108                         statement to this return indicating that 
exemption and the amount of adjusted                                                    the return position is treaty-based. See 
taxable gifts, exceeds the filing                                                       Regulations section 301.6114-1 for 
threshold of $60,000. The gift tax        Penalties                                     details.
specific exemption refers to the amount   Section 6651 provides for penalties for 
allowed for gifts made by the decedent    both late filing of returns and late          How To Complete Form 
between September 9, 1976, and            payment of tax unless there is                706-NA
December 31, 1976, inclusive. The         reasonable cause for the delay. There         Complete Form 706-NA in this order.
amount of adjusted taxable gifts refers   are also penalties for willful attempts to 
to the amount of adjusted taxable gifts   evade or defeat payment of tax.               1. Part I.
made by the decedent after December                                                     2. Part III.
31, 1976.                                 The law also provides for penalties 
                                          for valuation understatements that            3. Schedule A and B.
When To File                              cause an underpayment of tax. See 
                                                                                        4. Part II.
File Form 706-NA within 9 months after    sections 6662(g) and (h) for more 
the date of death unless an extension of  details.                                      The estate tax is imposed on the 
time to file was granted.                 Reasonable cause determinations.           If decedent's gross estate in the United 
If you are unable to file Form 706-NA     you receive a notice about penalties          States, reduced by allowable 
by the due date, use Form 4768,           after you file Form 706-NA, send an           deductions. Figure the gross estate in 
Application for Extension of Time To      explanation and we will determine if you      the United States on Schedule A. 
File a Return and/or Pay U.S. Estate      meet reasonable cause criteria. Do not        Reduce the Schedule A total by the 
(and Generation-Skipping Transfer)        attach an explanation when you file           allowable deductions to derive the 
Taxes, to apply for an automatic          Form 706-NA. Explanations attached to         taxable estate on Schedule B, and 
6-month extension of time to file. If you the return at the time of filing will not be  figure the tax due using Part II. Tax 
have already received a 6-month           considered.                                   Computation.
extension and are an executor who is      Return preparer. Estate tax return 
out of the country, you may apply for an  preparers who prepare any return or           Specific Instructions
additional extension of time to file by   claim for refund that reflects an 
filing a second Form 4768 and             understatement of tax liability due to an     Attachments
completing the form and attaching a       unreasonable position are subject to a        If the decedent died testate (with a 
written statement of explanation as       penalty equal to the greater of $1,000 or     legally valid will), attach a certified copy 
instructed. For both extensions, check    50% of the income earned (or to be            of the will to Form 706-NA. If you are 
                                          earned) for the preparation of each such      unable to obtain a certified copy, attach 

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a copy of the will and explain why it       More than one person to receive         Entire gross estate. The entire gross 
could not be certified.                       confidential information or represent   estate is figured the same way for a 
                                              the estate; or                          nonresident alien decedent as for a U.S. 
You must also attach a copy of the          Someone to sign agreements,             citizen or resident. It consists of all 
decedent's death certificate.                 consents, waivers, or other             property the decedent beneficially 
                                              documents for the estate.
For closely held or inactive corporate                                                owned, wherever located, and includes 
stock, attach the balance sheets,             If you wish only to authorize           the following property interests.
particularly the one nearest the              someone to inspect or receive           Generally, the full value of property 
valuation date, and statements of the         confidential tax information verbally     the decedent owned at the time of 
net earnings or operating results and         and/or in writing, complete and           death as a joint tenant with right of 
dividends paid for each of the 5              attach Form 8821, Tax Information         survivorship (but if the surviving 
preceding years. Attach any other             Authorization. Individuals                spouse is a U.S. citizen, then only 
documents, such as appraisals, needed         authorized by Form 8821 are not           half the value of property held by 
for explanation. Also attach copies of all    authorized to:                            the decedent and surviving spouse 
available U.S. gift tax returns the         Speak on behalf of the estate;            either as joint tenants with right of 
decedent filed. Other documents may         Execute a request to allow                survivorship or as tenants by the 
be required as explained in these             disclosure of tax return or tax return    entirety). For exceptions, see the 
instructions.                                 information to another third party;       Instructions for Form 706, 
                                            Advocate your position with respect       Schedule E.
Attach an English translation to all          to federal tax laws;                    Property the decedent and a 
documents in other languages.               Execute waivers, consents, closing        surviving spouse owned as 
                                              agreements; or                            community property to the extent of 
Part I. Decedent, Executor,                 Represent you in any other manner         the decedent's interest in the 
                                              before the IRS.                           property under applicable state, 
and Attorney                                                                            possession, or foreign law.
                                            Question 6a. If you answer “Yes,” 
Line 2. Enter the decedent's social                                                   A surviving spouse's dower or 
                                            please attach a statement listing:
security number (SSN), if applicable, or                                                curtesy interest and all substitute 
the decedent's individual taxpayer          The citizenship of the decedent's         interests created by statute.
                                              parents,
identification number (ITIN), but only if                                             Proceeds of insurance on the 
the decedent had previously used the        Whether the decedent became a             decedent's life, generally including 
                                              U.S. citizen through a naturalization 
ITIN to file other U.S. tax returns. If the                                             proceeds receivable by 
                                              proceeding in the United States, 
decedent does not have an SSN or a                                                      beneficiaries other than the estate.
                                              and
previously used ITIN, the IRS will assign                                             Several kinds of transfers the 
an Internal Revenue Service Number          When the decedent lost U.S.               decedent made before death.
                                              citizenship or residency.
(IRSN) to the decedent. If the decedent                                               Property in which the decedent 
has already been assigned an IRSN,          Question 6b. If you answered “Yes,”         either held a general power of 
please enter the number on line 2. If the   and the decedent lost his or her U.S.       appointment at the time of death, or 
decedent does not have an SSN, ITIN,        citizenship or long-term residence within   used or released this power in 
or an IRSN, leave line 2 blank and          10 years of death and prior to June 17,     certain ways before
complete in Part III.                       2008, but maintain that avoiding U.S.       death.
                                            taxes was not a principal purpose for     Certain annuities to surviving 
Part III. General                           the decedent's loss of citizenship or       beneficiaries.
Information                                 residency, attach documents to sustain    For additional information concerning 
                                            your position. See Definitions, earlier.  joint tenancies, tenancies by the 
Authorization. Completing the                                                         entirety, annuities, life insurance, 
authorization permits the attorney,         Question 9. A general power of 
accountant, enrolled agent, or other        appointment is any power of               transfers during life, and powers of 
representative indicated to represent       appointment exercisable in favor of the   appointment, see the Instructions for 
the estate before the IRS and receive       decedent, the decedent's estate, the      Form 706.
confidential tax information. It will not   decedent's creditors, or the creditors of Enter on Schedule A all of the assets 
authorize the representative to enter       the decedent's estate, and includes the   that meet both of the following tests.
into closing agreements for the estate.     right of a beneficiary to appropriate or  They are included in the entire 
                                            consume the principal of a trust. For a     gross estate.
Note. If you intend for the                 complete definition, see section          They are located in the United 
representative to represent the estate      2041(b).                                    States.
before the IRS, he or she must complete                                               Determining where assets are loca-
and sign this authorization. If you would   Schedule A. Gross Estate                  ted. Unless a treaty provides otherwise 
like to authorize your representative to    in the United States                      (see Death Tax Treaties, earlier), use 
perform other acts on behalf of the         Before you complete Schedule A, you       the following rules to determine whether 
estate, you must file Form 2848, Power      must determine what assets are            assets are located in the United States.
of Attorney and Declaration of              included in the decedent's entire gross 
Representative. Complete and attach         estate, wherever located. However, list   Real estate and tangible personal 
Form 2848 if you would like to authorize:   on Schedule A only those assets           property. Real estate and tangible 
Persons other than attorneys,             located in the United States. Enter the   personal property are located in the 
  accountants, or enrolled agents to        total value of assets located outside the United States if they are physically 
  represent the estate;                     United States on line 2 of Schedule B.    located there.

Instructions for Form 706-NA (Rev. 9-2021)                     -3-



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Note. An exception is made for works         exemption under section 871(h)(1)          Stocks.    In descriptions of stock, 
of art that are owned by a nonresident       had such interest been received by         include:
alien and are located within the United      the decedent at the time of his            The corporation's name;
States, if on the date of death the works    death. However, if the debt earns          The number of shares;
of art are:                                  contingent interest, some or all of it     Whether common or preferred (if 
Imported solely for public exhibition,     may be considered property in the            preferred, what issue);
On loan to a nonprofit public gallery      United States (section 2105(b)(3)).        The par value (when needed for 
  or museum, and                           Certain short-term original issue            identification);
On exhibition or en route to or from       discount debt obligations.                 Nine-digit CUSIP number (defined 
  exhibition.                              See section 2105(b)(4) for details.            later); and
                                                                                        The quotation at which reported.
Stock.      Generally, no matter where     Deposits.   The following deposits           Give the main exchange for listed 
stock certificates are physically located, are treated as located outside the           stock. For unlisted stock, give the post 
stock of corporations organized in or      United States if they are not effectively    office address of the main business 
under U.S. law is property located in the  connected with conducting a trade or         office of the corporation, the state in 
United States, and all other corporate     business within the United States.           which incorporated, and the 
stock is property located outside the      A deposit with a U.S. bank or a U.S.       incorporation date.
United States.                               banking branch of a foreign 
Stock in a regulated investment              corporation.                               Bonds.     In bond descriptions, 
company (RIC). For a nonresident           A deposit or withdrawable account          include:
alien decedent who died after 2004 and       with a savings and loan association        The quantity and denomination,
before 2012, a portion of stock in a RIC     chartered and supervised under             Obligor's name,
is treated as property located outside       federal or state law.                      Maturity date,
the United States in the proportion of the An amount held by a U.S. insurance         Interest rate,
RIC's qualifying assets in relation to the   company under an agreement to              Each date when interest is payable,
total assets owned by the RIC at the         pay interest.                              Nine-digit CUSIP number, and
end of the quarter immediately             A deposit in a foreign branch of a         Series number (if more than one 
preceding the decedent's death.              U.S. bank.                                   issue).
Qualifying assets are assets that, if      If an asset is included in the total         Give the exchange where the bond is 
owned directly by the decedent, would      gross estate because the decedent            listed. If it is unlisted, give the 
have been:                                 owned it at the time of death, apply the     corporation's main business office.
Bank deposits and amounts                above location rules as of the date of 
  described in section 871(i)(3),          the decedent's death. However, if an         CUSIP number.      The CUSIP 
Portfolio debt obligations,              asset is included in the decedent's total    (Committee on Uniform Security 
Certain original issue discount          gross estate under one of the transfer       Identification Procedures) number is a 
  obligations,                             provisions (sections 2035, 2036, 2037,       nine-digit number that is assigned to all 
Debt obligations of a U.S.               and 2038), it is treated as located in the   stocks and bonds traded on major 
  corporation that are treated as          United States if it fulfills these rules     exchanges and many unlisted 
  giving rise to foreign source income,    either at the time of the transfer or at the securities. Usually, the CUSIP number 
  and                                      time of death.                               is printed on the face of the stock 
                                                                                        certificate. If you do not have a stock 
Other property not within the United     For example, if an item of tangible          certificate, the CUSIP number may be 
  States.                                  personal property was physically             found on the broker's or custodian's 
See section 2105(d) for details.           located in the United States on the date     statement or by contacting the 
                                           of a section 2038 transfer but had been      company's transfer agent.
Insurance proceeds. Proceeds of            moved outside the United States at the 
insurance policies on the decedent's life  time of the decedent's death, the item       Schedules E, G, or H.    If you are 
are property located outside the United    would be considered still located in the     required to file Schedule E, G, or H from 
States.                                    United States and should be listed on        Form 706, you do not need to enter the 
Debt obligations within United             Schedule A.                                  assets reported on those schedules on 
States. Debt obligations are generally     If the decedent was a U.S.                   Schedule A of this Form 706-NA. 
property located in the United States if   expatriate, the decedent is treated as       Instead, attach the schedules to Form 
they are debts of a U.S. citizen or        owning a prorated share of the U.S.          706-NA, in column (b) enter “Total from 
resident, a domestic partnership or        property held by a foreign corporation in    Schedule __, Form 706,” and enter the 
corporation, a domestic estate or trust,   which he or she directly or indirectly       total values from the attached 
the United States, a state or state's      owned at least 10% of the voting stock       schedules in either column (d) or (e).
political subdivision, or the District of  and, directly, indirectly, or                Property valuation date. Generally, 
Columbia.                                  constructively, owned more than 50% of       property must be valued as of the date 
                                           the stock by vote or value (section          of death. Columns (c) and (d) do not 
Debt obligations outside United            2107(b)).                                    apply in this case, and you may use the 
States. The following debt obligations                                                  space to expand descriptions from 
are generally treated as located outside   Describe the property on Schedule A 
the United States.                         in enough detail to enable the IRS to        column (b).
Debt obligations (whether                identify it. To determine the fair market    However, you may elect to use the 
  registered or unregistered) issued       value of stocks and bonds, use the rules     alternate valuation date. To make this 
  after July 18, 1984, if the interest on  in the Instructions for Form 706,            election, check the “Yes” box at the 
  them would be eligible for tax           Schedule B—Stocks and Bonds.                 beginning of Schedule A. If you do so, 

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the election applies to all property, and  treaty places a limit on the amount of     included in the total gross estate on 
you will need to complete each column      U.S. estate tax owed on such property.     line 3. Do not deduct tax on income 
in Schedule A. Under this election, any    The tax may not exceed the U.S. estate     received after death or property taxes 
property distributed, sold, exchanged,     tax that could have been imposed on        accrued after death. See Line 7, later, 
or otherwise disposed of within 6          the decedent’s worldwide assets had        for details on deducting death taxes.
months after the decedent's death is       the decedent died domiciled in the         On line 4, show the total of these 
valued as of the date of the disposition.  United States. If the amount of tax on     deductible items. In general, the total is 
Any property not disposed of during that   the property exceeds that limit, the       limited to the amount on line 3.
period is valued as of the date 6 months   lower amount may be reported as the 
after the decedent's death.                tax due on the Form 706-NA. You must       To document the line 4 amount, 
You may not elect alternate valuation      attach to the estate's Form 706-NA a       attach an itemized schedule. For each 
unless the election will decrease both     statement showing the alternate            expense or claim, specify the nature 
the value of the gross estate and the net  computation and claiming the benefit of    and amount and give the creditor's 
estate tax due after application of all    the treaty provision. See Paragraph 5 of   name. Describe other deductions fully 
allowable credits.                         Article 8 of the treaty.                   and identify any particular property to 
                                                                                      which they relate.
Qualified Conservation                     Schedule B. Taxable                        Line 6. Use line 6 to enter the following 
Easement Exclusion                         Estate                                     deductions.
Under section 2031(c), you may elect to                                               Charitable deduction.         Unless a 
exclude a portion of the value of land             For the line 5 deduction to be 
                                                                                      treaty allows otherwise, you may take a 
that is subject to a qualified                !    allowed, you must complete         charitable deduction only if the transfer 
conservation easement. You make the        CAUTION lines 1 through 4 and document 
election by attaching Schedule U of        the amounts you include on lines 2 and     was to a domestic entity or for use in the 
Form 706 with all the required             4.                                         United States as described in the 
                                                                                      Instructions for Form 706.
information. To elect the exclusion, you 
                                           Line 2. The amount on line 2 is the total  Attach Schedule O of Form 706. If 
must include on Schedule A:
                                           value of the assets included in the entire you claim the deduction under a treaty, 
1. The decedent's interest in the land     gross estate that were located outside     specify the applicable treaty and attach 
that is subject to the exclusion, and      the United States.                         a computation of the deduction.
2. Exclude the applicable value of the        To document the line 2 amount,          Marital deduction.          Unless a treaty 
land (amount from line 20 of               attach a certified copy of the foreign     allows otherwise, you may only take a 
Schedule U) that is subject to the         death tax return or, if none was filed, a  marital deduction if the surviving spouse 
easement on Schedule A.                    certified copy of the estate inventory     is a U.S. citizen or if the property passes 
                                           and the schedule of debts and charges      to a qualified domestic trust (QDOT) 
You must make the election on a            that were filed with the foreign probate   described in section 2056A and an 
timely filed Form 706-NA, including        court or as part of the estate's           election is made on Schedule M of Form 
extensions. For more information, see      administration proceedings.                706. See Regulations section 
the Instructions for Form 706.             Supplement these documents with            20.2056A-2(d) for additional QDOT 
                                           attachments if they do not set forth the 
Canadian Small Estate Relief                                                          requirements.
                                           entire gross estate outside the United 
If you are claiming a small estate         States. If more proof is needed, you will  Attach Schedule M of Form 706 and 
exemption (worldwide estate of a           be notified.                               a statement showing your computation 
Canadian resident decedent not more                                                   of the marital deduction.
than $1.2 million) from tax on U.S.           If you elected the alternate valuation 
securities or certain other U.S. situs     date for property listed on Schedule A,    See section 2518 for the rules 
property under the 1995 Protocol to the    use it also for the assets reported on     governing disclaimers of interests in 
Canadian income tax treaty, do not list    line 2. Otherwise, value the amounts as    property.
the exempt assets on Schedule A.           of the date of death.                      Line 7. You may take a deduction on 
                                           Line 4. You may deduct the following       line 7 for death taxes (estate, 
Instead, list those assets and their       items whether or not they were incurred    inheritance, legacy, or succession 
values in a statement attached to the      or paid in the United States.              taxes) you paid to any state or the 
return specifying that you are relying on   Funeral expenses.                       District of Columbia on property listed in 
the treaty. To determine initially whether  Administration expenses.                Schedule A. To calculate the deduction 
the small estate exemption applies,         Claims against the estate.              for state death taxes, use the formula 
however, you must include the exempt        Unpaid mortgages and liens.             below. Enter the result on line 7.
assets in the value of the entire gross     Uncompensated losses that were          Total value of assets               
estate, wherever located, on lines 2 and      incurred during settlement of the       in the gross estate subject     Total state 
3 of Schedule B.                              estate and that arose from theft or     to state death taxes        x death taxes 
United States–United Kingdom                  from casualties, such as fires,         Gross estate located in the        paid
                                              storms, or shipwrecks.                  United States (line 1 of 
Treaty                                                                                Schedule B)
                                              You may deduct only that part of a 
If a decedent who was a U.K. national, 
                                           debt or mortgage that was contracted in 
but was neither domiciled in nor a 
                                           good faith and for full value in money or 
national of the United States, has                                                    Generally, you must claim this 
                                           money's worth. You may deduct 
property that is subject to U.S. estate                                               deduction within 4 years of filing the 
                                           mortgages only to the extent of the full 
tax under the terms of the United                                                     return. However, see section 2058(b) 
                                           value of the mortgaged property 
States–United Kingdom Treaty, the                                                     for exceptions and periods of limitations.

Instructions for Form 706-NA (Rev. 9-2021)                    -5-



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For the deduction to be allowed, you       Line 9.  Use line 9 to enter the following  million. The $100 million or more 
must file a certificate signed by the      credits.                                    amount limit does not apply to other 
appropriate official of the taxing state.                                              methods of payment (such as electronic 
The certificate should show:               Credit for federal gift taxes.       See    payments).
The total tax charged,                   sections 2102 and 2012. Attach 
Any discount allowed,                    computation of credit.                      Signature(s)
Any penalties and interest imposed,      Canadian marital credit.  In                        If there is more than one 
The tax actually paid, and               addition to the unified credit, a           !       executor, all listed executors are 
Each payment date.                       nonrefundable marital credit may be         CAUTION responsible for the return. 
If possible, attach the certificate to     allowed if the executor elects this treaty  However, it is sufficient for only one of 
this return; otherwise, please file it as  benefit and waives the benefit of any       the co-executors to sign the return.
soon as possible.                          estate tax marital deduction allowable 
If you later recover any of the state      under U.S. law. The credit amount is        Form 706-NA must be signed. The 
tax for which you claim this deduction,    generally limited to the lesser of:         executor must verify and sign the 
you must notify the IRS at the following   The unified credit allowed to the         declaration on page 1 under penalties of 
address within 30 days of receiving any      estate (before reduction for any gift     perjury. The executor may use Form 
refund of state taxes.                       tax unified credit), or                   2848 to authorize another person to act 
                                           The amount of estate tax that would       for him or her before the IRS. See the 
  Department of the Treasury                 otherwise be imposed by the United        instructions for the authorization in Part 
  Internal Revenue Service Center            States on the transfer of qualifying      III. General Information, earlier, or the 
  Kansas City, MO 64999                      property to the surviving spouse.         Instructions for Form 2848 and Circular 
                                                                                       230, Regulations Governing Practice 
                                           See the 1995 Canadian income tax            before the Internal Revenue Service, 
Part II. Tax Computation                   treaty protocol for details on computing    section 10.7(c)(1)(vii), for information on 
                                           the credit. Also, attach a computation of   representing a person or entity located 
Lines 4 and 5. To determine the            the credit, and on the dotted line to the   outside the United States.
tentative tax on the amount on line 2 (to  left of the line 9 entry, enter “Canadian 
be entered on line 5) and the tentative    marital credit.”                            Third-party designee.   If you want to 
tax on the amount on line 3 (to be                                                     allow the return preparer (listed on the 
entered on line 4), use Table A—Unified    Line 13. If you answered “Yes” to           bottom of page 1 of Form 706-NA) to 
Rate Schedule in the version of the        question 11 of Part III, you must           discuss your Form 706-NA with the IRS, 
Instructions for Form 706 that             complete and attach Schedules R             check the "Yes" box to the far right of 
corresponds to the decedent's date of      and/or R-1 from Form 706.                   your signature on page 1 of your return. 
death.                                     For the purposes of Form 706-NA,            If you check the "Yes" box, you are 
Line 7. Enter the unified credit. The      the GST tax is imposed only on              authorizing the IRS to call your return 
unified credit is allowed for the smaller  transfers of interests in property that are preparer to answer questions that may 
of the line 6 amount or the maximum        part of the gross estate in the United      arise during the processing of your 
unified credit. In general, the maximum    States. Therefore, when completing          return. You are also authorizing the 
unified credit is $13,000.                 Schedules R and/or R-1, you should          return preparer of your Form 706-NA to:
                                           enter only transfers of interests in        Give the IRS any information that is 
For a citizen of a U.S. possession         property that you listed on Schedule A        missing from your return;
(see section 2209), the maximum            of Form 706-NA. Otherwise, complete         Call the IRS for information about 
unified credit is the greater of:          Schedules R and/or R-1 according to           the processing of your return or the 
$13,000, or                              their instructions and enter the total GST    status of your payment(s);
The product of $46,800 times a           tax from Schedule R on line 13.             Receive copies of notices or 
  fraction.
                                           For details, see Regulations section          transcripts related to your return, 
The numerator of the fraction is the       26.2663-2.                                    upon request; and
part of the gross estate located in the                                                Respond to certain IRS notices 
United States (line 1 of Schedule B),      Line 15. Attach an explanation if earlier     about math errors, offsets, and 
and the denominator is the entire gross    payments were made to the IRS.                return preparation.
estate wherever located (line 3 of         Line 16. Pay the balance due within 9       You are not authorizing your return 
Schedule B).                               months after the decedent's death           preparer to receive any refund check, to 
If the unified credit is affected by a     unless an extension of time to pay was      bind you to anything (including any 
treaty, see section 2102(b)(3)(A).         granted. Make the check or money            additional tax liability), or otherwise 
                                           order payable to “United States             represent you before the IRS. If you 
Note. At the time this form went to print, Treasury” for the face value in U.S.        want to expand the authorization of your 
treaties with Australia, Canada, Finland,  dollars.                                    return preparer, see Pub. 947, Practice 
France, Germany, Greece, Italy, Japan,                                                 Before the IRS and Power of Attorney. 
and Switzerland contained provisions to    No checks of $100 million or more 
which section 2102(b)(3)(A) applies.       accepted.  The IRS cannot accept a          The authorization will automatically end 
                                           single check (including a cashier's         3 years from the date of filing Form 
        Any amount previously allowed      check) for amounts of $100,000,000          706-NA. If you wish to revoke the 
!       as a unified credit against the    ($100 million) or more. If you're sending   authorization before it ends, see Pub. 
CAUTION gift tax will reduce, dollar for   $100 million or more by check, you'll       947.
dollar, the unified credit allowed the     need to spread the payments over two 
                                                                                       Generally, anyone who is paid to 
estate (section 2102(b)(3)(B)).            or more checks, with each check made 
                                                                                       prepare the return must sign the return 
                                           out for an amount less than $100 
                                                                                       in the space provided and fill in the Paid 

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Preparer Use Only area. See section      preparer must give a copy of the   Note. A paid preparer may sign original 
7701(a)(36)(B) for exceptions.           completed return to the executor.  or amended returns by rubber stamp, 
   In addition to signing and completing                                    mechanical device, or computer 
the required information, the paid                                          software program.

Privacy Act and Paperwork Reduction Act Notice.   We ask for the information on this form to carry out the Internal Revenue 
laws of the United States. You are required to give us the information. We need it to ensure that you are complying with these 
laws and to allow us to figure and collect the right amount of tax. Subtitle B and section 6109, and the regulations, require you 
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Comments and suggestions. We welcome your comments about these instructions and your suggestions for future editions. 
You can send us comments through IRS.gov/FormComments. Or, you can write to:
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   Tax Forms and Publications Division
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comments as we revise our tax forms, instructions, and publications. Do not send the tax form to this address. Instead, see 
Where To File, earlier.

Instructions for Form 706-NA (Rev. 9-2021)               -7-






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