Instructions for Form 706-NA

(Rev. October 2022)

United States Estate (and Generation-Skipping Transfer) Tax Return

Estate of nonresident not a citizen of the United States

Department of the Treasury

Internal Revenue Service

Section references are to the Internal Revenue Code 

unless otherwise noted.

Future Developments

For the latest information about developments related to 

Form 706-NA and its instructions, such as legislation 

enacted after they were published, go to IRS.gov/

Form706NA.

What’s New

Estate tax closing letter fee. Effective October 28, 

2021, a user fee of $67 was established for persons 

requesting the issuance of an estate tax closing letter 

(ETCL). See ETCL fee, later, for more information.

General Instructions

Purpose of Form

Form 706-NA is used to compute estate and 

generation-skipping transfer (GST) tax liability for 

nonresident not a citizen (NRNC) decedents. The estate 

tax is imposed on the transfer of the decedent's taxable 

estate rather than on the receipt of any part of it.

For information about transfer certificates for U.S. 

assets, write to the following address.

Internal Revenue Service

Attn: E&G, Stop 824G

7940 Kentucky Drive

Florence, KY 41042-2915

Note. In order to complete this return, you must obtain 

Form 706, United States Estate (and Generation-Skipping 

Transfer) Tax Return, and its instructions. You must attach 

schedules from Form 706 if you intend to claim a marital 

deduction, a charitable deduction, a qualified 

conservation easement exclusion, or a credit for tax on 

prior transfers, or if you answer “Yes” to question 5, 7, 8, 

9a, 9b, or 11 in Part III. General Information. You will need 

the Instructions for Form 706 to explain how to value 

stocks and bonds. Make sure that you use the version of 

Form 706 that corresponds to the date of the decedent's 

death.

Consistent Basis Reporting

Estates are required to report to the IRS and the recipient 

the estate tax value of each asset included in the gross 

estate within 30 days of filing Form 706-NA, or earlier if 

the return is filed late. The basis of certain assets when 

sold or otherwise disposed of must be consistent with the 

basis (estate tax value) of the asset when it was received 

TIP

by the beneficiary. To satisfy the consistent basis 

reporting requirements, the estate must file Form 8971, 

Information Regarding Beneficiaries Acquiring Property 

From a Decedent. See Form 8971 and its instructions.

Estate Tax Closing Letters

An estate tax closing letter (ETCL) will not be issued 

unless a request is made via Pay.gov. To allow time for 

processing, please wait at least 9 months after filing Form 

706-NA to request an estate tax closing letter.

ETCL fee. Effective October 28, 2021, final regulations 

TD 9957 established a user fee of $67 for persons 

requesting the issuance of an ETCL. To make an ETCL 

request after October 28, 2021, you must go to Pay.gov to 

submit a request and pay the user fee. Go to Frequently 

Asked Questions on the Estate Tax Closing Letter, for 

instructions and more information related to ETCLs.

Account transcripts in lieu of ETCL. Instead of an 

ETCL, the executor of the estate may request an account 

transcript, which reflects transactions including the 

acceptance of Form 706-NA or the completion of an 

examination. Account transcripts are available online to 

registered tax professionals using the Transcript Delivery 

System (TDS) or to authorized representatives making 

requests using Form 4506-T. Go to Transcripts in Lieu of 

Estate Tax Closing Letters for specific instructions to 

request online transcripts using the TDS or hardcopy 

transcripts using Form 4506-T.

Definitions

The following definitions apply in these instructions.

United States. The United States means the 50 states 

and the District of Columbia.

Domicile. For estate tax purposes, a person acquires 

domicile in a place by living there, for even a brief period 

of time, with no definite present intention of later moving. 

For this purpose, the United States includes only the 

states and the District of Columbia. See Regulations 

section 20.0-1 for more information.

Nonresident not a citizen (NRNC) of the United 

States. For estate tax purposes, a decedent is an NRNC 

of the United States if the decedent is neither domiciled in 

nor a citizen of the United States at the time of death. A 

decedent who acquired U.S. citizenship solely by reason 

of being a citizen of a U.S. territory or by reason of birth or 

residence within a U.S. territory is not treated as a U.S. 

citizen.

Note. A decedent may be a U.S. resident for income tax 

purposes yet be considered a nonresident for estate tax 

purposes.

Long-term U.S. resident. A long-term U.S. resident is 

an individual (other than a U.S. citizen) who has been a 

Sep 19, 2022 Cat. No. 63118N
lawful permanent resident of the United States (green 

card holder) for income tax purposes in at least 8 of the 

last 15 tax years ending with the tax year in which U.S. 

income tax residency is terminated. See section 877(e) for 

more information.

Executor. An executor is the personal representative, 

executor, executrix, administrator, or administratrix of the 

deceased person's estate. If no executor is appointed, 

qualified, and acting in the United States, every person in 

actual or constructive possession of any of the decedent's 

property must file a return. If more than one person must 

file, it is preferable that they join in filing one complete 

return. Otherwise, each must file as complete a return as 

possible, including a full description of the property and 

each person's name who holds an interest in it.

Executors must provide documentation proving their 

status. Documentation will vary but may include a certified 

copy of the will or a court order designating the 

executor(s). A statement by the executor(s) attesting to 

their status is insufficient.

U.S. expatriate. Special estate tax rules may apply to 

decedents who expatriated from the United States prior to 

death. For these purposes, both U.S. citizens who 

relinquished their citizenship and long-term residents who 

have surrendered their green card or taken a position 

under a tax treaty that they are solely a resident of the 

other country, are treated as expatriates.

For decedents who expatriated prior to June 17, 2008, 

and were still subject to the 10-year alternative tax regime 

of section 877(b) on the date of death, the rules in section 

2107 apply to determine the value of the decedent’s U.S. 

taxable estate. For decedents who expatriated on or after 

June 17, 2008, and were “covered expatriates” on the 

date of death, as defined in section 877A(g)(1), the rules 

in section 2107 do not apply, but the rules of section 2801 

may apply. So decedents who expatriated on or after 

June 17, 2008, are generally subject to U.S. estate tax as 

all other NRNC decedents, and the references to “U.S. 

expatriate” in these instructions refer only to decedents 

who expatriated prior to June 17, 2008. See the 

instructions for Question 6a and Question 6b, later. Also, 

see effective dates, later, for more information.

Expatriation after June 3, 2004, but before June 17, 

2008. A decedent would have been subject to the 

10-year alternative tax regime of section 877(b) if the 

individual met one of three tests set out under section 

877(a) relating to:

1. Average annual net income tax liability,

2. Net worth, and

3. Certification of tax compliance.

See sections 877 and 2107 and Form 8854, Initial and 

Annual Expatriation Statement, as they existed in the 

relevant tax year for additional information.

Expatriation on or after February 6, 1995, through 

June 3, 2004. A decedent would have been presumed to 

be subject to the 10-year alternative tax regime of section 

877(b) if the individual's average annual net income tax 

liability or net worth exceeded certain limits, absent a 

private letter ruling reversing the presumption. See 

sections 877 and 2107 and Form 8854 as they existed in 

the relevant tax year for additional information.

Who Must File

The executor must file Form 706-NA if the date of death 

value of the decedent’s U.S.-situated assets, together 

with the gift tax specific exemption and the amount of 

adjusted taxable gifts, exceeds the filing threshold of 

$60,000. The gift tax specific exemption refers to the 

amount allowed for gifts made by the decedent between 

September 9, 1976, and December 31, 1976, inclusive. 

The amount of adjusted taxable gifts refers to the amount 

of adjusted taxable gifts made by the decedent after 

December 31, 1976.

When To File

File Form 706-NA within 9 months after the date of death 

unless an extension of time to file was granted.

If you are unable to file Form 706-NA by the due date, 

use Form 4768, Application for Extension of Time To File 

a Return and/or Pay U.S. Estate (and 

Generation-Skipping Transfer) Taxes, to apply for an 

automatic 6-month extension of time to file. If you have 

already received a 6-month extension and are an 

executor who is out of the country, you may apply for an 

additional extension of time to file by filing a second Form 

4768 and completing the form and attaching a written 

statement of explanation as instructed. For both 

extensions, check the “Form 706-NA” box in Part II of 

Form 4768.

Private delivery services (PDSs). You can use certain 

PDSs designated by the IRS to meet the "timely mailing 

as timely filing/paying" rule for tax returns and payments. 

Go to IRS.gov/PDS for the current list of designated 

services.

The PDS can tell you how to get written proof of the 

mailing date.

For the IRS mailing address to use if you're using a 

PDS, go to IRS.gov/PDSStreetAddresses.

PDSs can’t deliver items to P.O. boxes. You must 

use the U.S. Postal Service to mail any item to an 

IRS P.O. box address.

Where To File

File Form 706-NA at the following address.

Department of the Treasury

Internal Revenue Service Center

Kansas City, MO 64999

If using a PDS, use this address.

Internal Revenue Submission Processing Center

333 W. Pershing

Kansas City, MO 64108

Penalties

Section 6651 provides for penalties for both late filing of 

returns and late payment of tax unless there is reasonable 

cause for the delay. There are also penalties for willful 

attempts to evade or defeat payment of tax.

CAUTION

!

-2- Instructions for Form 706-NA (Rev. 10-2022)
The law also provides for penalties for valuation 

understatements that cause an underpayment of tax. See 

sections 6662(g) and (h) for more details.

Reasonable-cause determinations. If you receive a 

notice about penalties after you file Form 706-NA, send an 

explanation, and we will determine if you meet 

reasonable-cause criteria. Do not attach an explanation 

when you file Form 706-NA. Explanations attached to the 

return at the time of filing will not be considered.

Return preparer. Estate tax return preparers who 

prepare any return or claim for refund that reflects an 

understatement of tax liability due to an unreasonable 

position are subject to a penalty equal to the greater of 

$1,000 or 50% of the income earned (or to be earned) for 

the preparation of each such return. Estate tax return 

preparers who prepare any return or claim for refund that 

reflects an understatement of tax liability due to willful or 

reckless conduct are subject to a penalty of $5,000 or 

75% of the income earned (or income to be earned), 

whichever is greater, for the preparation of each such 

return. See section 6694(a) and 6694(b), the related 

regulations, and Announcement 2009-15, 2009-11 I.R.B. 

687, available at Announcement 2009-15, for more 

information.

Death Tax Treaties

Death tax treaties are in effect with the following countries.

Australia Ireland 

Austria Italy 

Canada* Japan 

Denmark Netherlands 

Finland South Africa

France Switzerland

Germany United Kingdom

Greece

 *Article XXIX B of the United States–Canada Income Tax Treaty

If you are reporting any items on this return based on 

the provisions of a death tax treaty or protocol, attach a 

statement to this return indicating that the return position 

is treaty based. See Regulations section 301.6114-1 for 

details.

How To Complete Form 706-NA

Complete Form 706-NA in this order.

1. Part I.

2. Part III.

3. Schedule A and B.

4. Part II.

The estate tax is imposed on the decedent's gross 

estate in the United States, reduced by allowable 

deductions. Figure the gross estate in the United States 

on Schedule A. Reduce the Schedule A total by the 

allowable deductions to derive the taxable estate on 

Schedule B, and figure the tax due using Part II. Tax 

Computation.

Specific Instructions

Attachments

If the decedent died testate (with a legally valid will), 

attach a certified copy of the will to Form 706-NA. If you 

are unable to obtain a certified copy, attach a copy of the 

will and explain why it could not be certified.

You must also attach a copy of the decedent's death 

certificate.

For closely held or inactive corporate stock, attach the 

balance sheets, particularly the one nearest the valuation 

date, and statements of the net earnings or operating 

results and dividends paid for each of the 5 preceding 

years. Attach any other documents, such as appraisals, 

needed for explanation. Also attach copies of all available 

U.S. gift tax returns the decedent filed. Other documents 

may be required as explained in these instructions.

Attach an English translation to all documents in other 

languages.

Part I. Decedent, Executor, and 

Attorney

Line 2. Enter the decedent's social security number 

(SSN), if applicable, or the decedent's individual taxpayer 

identification number (ITIN), but only if the decedent had 

previously used the ITIN to file other U.S. tax returns. If the 

decedent does not have an SSN or a previously used 

ITIN, the IRS will assign an Internal Revenue Service 

Number (IRSN) to the decedent. If the decedent has 

already been assigned an IRSN, please enter the number 

on line 2. If the decedent does not have an SSN, ITIN, or 

an IRSN, leave line 2 blank.

Part III. General Information

Authorization. Completing the authorization permits the 

attorney, accountant, enrolled agent, or other 

representative indicated to represent the estate before the 

IRS and receive confidential tax information. It will not 

authorize the representative to enter into closing 

agreements for the estate.

If you intend for the representative to represent the 

estate before the IRS, the representative must complete 

and sign this authorization. If you would like to authorize 

your representative to perform other acts on behalf of the 

estate, you must file Form 2848, Power of Attorney and 

Declaration of Representative. Complete and attach Form 

2848 if you would like to authorize:

• Persons other than attorneys, accountants, or enrolled 

agents to represent the estate;

• More than one person to receive confidential 

information or represent the estate; or

• Someone to sign agreements, consents, waivers, or 

other documents for the estate.

If you wish only to authorize someone to inspect or 

receive confidential tax information verbally and/or in 

writing, complete and attach Form 8821, Tax Information 

Authorization. Individuals authorized by Form 8821 are 

not authorized to:

• Speak on behalf of the estate;

Instructions for Form 706-NA (Rev. 10-2022) -3-
• Execute a request to allow disclosure of tax return or 

tax return information to another third party;

• Advocate your position with respect to federal tax 

laws;

• Execute waivers, consents, closing agreements; or

• Represent you in any other manner before the IRS.

Question 6a. If you answer “Yes,” please attach a 

statement listing:

• The citizenship of the decedent's parents,

• Whether the decedent became a U.S. citizen through 

a naturalization proceeding in the United States, and

• When the decedent lost U.S. citizenship or residency.

Question 6b. If you answered “Yes,” and the decedent 

lost U.S. citizenship or long-term resident status within 10 

years of death and prior to June 17, 2008, but you 

maintain that avoiding U.S. taxes was not a principal 

purpose for the decedent's loss of citizenship or 

residency, attach documents to sustain your position. See 

Definitions, earlier.

Question 9. A general power of appointment is any 

power of appointment exercisable in favor of the 

decedent, the decedent's estate, the decedent's creditors, 

or the creditors of the decedent's estate, and includes the 

right of a beneficiary to appropriate or consume the 

principal of a trust. For a complete definition, see section 

2041(b).

Schedule A. Gross Estate in the 

United States

Before you complete Schedule A, you must determine 

what assets are included in the decedent's entire gross 

estate, wherever located. However, list on Schedule A 

only those assets located in the United States. Enter the 

total value of assets located outside the United States on 

line 2 of Schedule B.

Entire gross estate. The entire gross estate is figured 

the same way for an NRNC decedent as for a U.S. citizen 

or resident. It consists of all property the decedent 

beneficially owned, wherever located, and includes the 

following property interests.

• Generally, the full value of property the decedent 

owned at the time of death as a joint tenant with right 

of survivorship (but if the surviving spouse is a U.S. 

citizen, then only half the value of property held by the 

decedent and surviving spouse either as joint tenants 

with right of survivorship or as tenants by the entirety). 

For exceptions, see the Instructions for Form 706, 

Schedule E.

• Property the decedent and a surviving spouse owned 

as community property to the extent of the decedent's 

interest in the property under applicable state, 

possession, or foreign law.

• A surviving spouse's dower or curtesy interest and all 

substitute interests created by statute.

• Proceeds of insurance on the decedent's life, 

generally including proceeds receivable by 

beneficiaries other than the estate.

• Several kinds of transfers the decedent made before 

death.

• Property in which the decedent either held a general 

power of appointment at the time of death, or used or 

released this power in certain ways before death.

• Certain annuities to surviving beneficiaries.

For additional information concerning joint tenancies, 

tenancies by the entirety, annuities, life insurance, 

transfers during life, and powers of appointment, see the 

Instructions for Form 706.

Enter on Schedule A all of the assets that meet both of 

the following tests.

• They are included in the entire gross estate.

• They are located in the United States.

Determining where assets are located. Unless a treaty 

provides otherwise (see Death Tax Treaties, earlier), use 

the following rules to determine whether assets are 

located in the United States.

Real estate and tangible personal property. Real 

estate and tangible personal property are located in the 

United States if they are physically located there.

Note. An exception is made for works of art that are 

owned by an NRNC decedent and are located within the 

United States, if on the date of death the works of art are:

• Imported solely for public exhibition,

• On loan to a nonprofit public gallery or museum, and

• On exhibition or en route to or from exhibition.

Stock. Generally, no matter where stock certificates 

are physically located, stock of corporations organized in 

or under U.S. law is property located in the United States, 

and all other corporate stock is property located outside 

the United States.

Stock in a regulated investment company (RIC). 

For an NRNC decedent who died after 2004 and before 

2012, a portion of stock in a RIC is treated as property 

located outside the United States in the proportion of the 

RIC's qualifying assets in relation to the total assets 

owned by the RIC at the end of the quarter immediately 

preceding the decedent's death.

Qualifying assets are assets that, if owned directly by 

the decedent, would have been:

• Bank deposits and amounts described in section 

871(i)(3),

• Portfolio debt obligations,

• Certain original issue discount obligations,

• Debt obligations of a U.S. corporation that are treated 

as giving rise to foreign source income, and

• Other property not within the United States.

See section 2105(d) for details.

Insurance proceeds. Proceeds of insurance policies 

on the decedent's life are property located outside the 

United States.

Debt obligations within United States. Debt 

obligations are generally property located in the United 

States if they are debts of a U.S. citizen or resident, a 

domestic partnership or corporation, a domestic estate or 

trust, the United States, a state or state's political 

subdivision, or the District of Columbia.

-4- Instructions for Form 706-NA (Rev. 10-2022)
Debt obligations outside United States. The 

following debt obligations are generally treated as located 

outside the United States.

• Debt obligations (whether registered or unregistered) 

issued after July 18, 1984, if the interest on them 

would be eligible for tax exemption under section 

871(h)(1) had such interest been received by the 

decedent at the time of the decedent’s death. 

However, if the debt earns contingent interest, some 

or all of it may be considered property in the United 

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

• Certain short-term original issue discount debt 

obligations.

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

Deposits. The following deposits are treated as 

located outside the United States if they are not effectively 

connected with conducting a trade or business within the 

United States.

• A deposit with a U.S. bank or a U.S. banking branch of 

a foreign corporation.

• A deposit or withdrawable account with a savings and 

loan association chartered and supervised under 

federal or state law.

• An amount held by a U.S. insurance company under 

an agreement to pay interest.

• A deposit in a foreign branch of a U.S. bank.

If an asset is included in the total gross estate because 

the decedent owned it at the time of death, apply the 

above location rules as of the date of the decedent's 

death. However, if an asset is included in the decedent's 

total gross estate under one of the transfer provisions 

(sections 2035, 2036, 2037, and 2038), it is treated as 

located in the United States if it fulfills these rules either at 

the time of the transfer or at the time of death.

For example, if an item of tangible personal property 

was physically located in the United States on the date of 

a section 2038 transfer but had been moved outside the 

United States at the time of the decedent's death, the item 

would be considered still located in the United States and 

should be listed on Schedule A.

If the decedent was a U.S. expatriate subject to 877(b) 

at the time of death, the decedent is treated as owning a 

prorated share of the U.S. property held by a foreign 

corporation in which the decedent directly or indirectly 

owned at least 10% of the voting stock and, directly, 

indirectly, or constructively, owned more than 50% of the 

stock by vote or value (section 2107(b)).

Describe the property on Schedule A in enough detail 

to enable the IRS to identify it. To determine the fair 

market value of stocks and bonds, use the rules in the 

Instructions for Form 706, Schedule B—Stocks and 

Bonds.

Stocks. In descriptions of stock, include:

• The corporation's name;

• The number of shares;

• Whether common or preferred (if preferred, what 

issue);

• The par value (when needed for identification);

• Nine-digit CUSIP number (defined later); and

• The quotation at which reported.

Give the main exchange for listed stock. For unlisted 

stock, give the post office address of the main business 

office of the corporation, the state in which incorporated, 

and the incorporation date.

Bonds. In bond descriptions, include:

• The quantity and denomination,

• Obligor's name,

• Maturity date,

• Interest rate,

• Each date when interest is payable,

• Nine-digit CUSIP number, and

• Series number (if more than one issue).

Give the exchange where the bond is listed. If it is 

unlisted, give the corporation's main business office.

CUSIP number. The CUSIP (Committee on Uniform 

Security Identification Procedures) number is a nine-digit 

number that is assigned to all stocks and bonds traded on 

major exchanges and many unlisted securities. Usually, 

the CUSIP number is printed on the face of the stock 

certificate. If you do not have a stock certificate, the 

CUSIP number may be found on the broker's or 

custodian's statement or by contacting the company's 

transfer agent.

Schedules E, G, or H. If you are required to file 

Schedule E, G, or H from Form 706, you do not need to 

enter the assets reported on those schedules on 

Schedule A of this Form 706-NA. Instead, attach the 

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

from Schedule __, Form 706,” and enter the total values 

from the attached schedules in either column (d) or (e).

Property valuation date. Generally, property must be 

valued as of the date of death. Columns (c) and (d) do not 

apply in this case, and you may use the space to expand 

descriptions from column (b).

However, you may elect to use the alternate valuation 

date. To make this election, check the “Yes” box at the 

beginning of Schedule A. If you do so, the election applies 

to all property, and you will need to complete each column 

in Schedule A. Under this election, any property 

distributed, sold, exchanged, or otherwise disposed of 

within 6 months after the decedent's death is valued as of 

the date of the disposition. Any property not disposed of 

during that period is valued as of the date 6 months after 

the decedent's death.

You may not elect alternate valuation unless the 

election will decrease both the value of the gross estate 

and the net estate tax due after application of all allowable 

credits.

Qualified Conservation Easement Exclusion

Under section 2031(c), you may elect to exclude a portion 

of the value of land that is subject to a qualified 

conservation easement. You make the election by 

attaching Schedule U of Form 706 with all the required 

information. To elect the exclusion, you must include on 

Schedule A:

1. The decedent's interest in the land that is subject to 

the exclusion, and

2. Exclude the applicable value of the land (amount from 

line 20 of Schedule U) that is subject to the easement 

on Schedule A.

Instructions for Form 706-NA (Rev. 10-2022) -5-
You must make the election on a timely filed Form 

706-NA, including extensions. For more information, see 

the Instructions for Form 706.

Canadian Small Estate Relief

If you are claiming a small estate exemption (worldwide 

estate of a Canadian resident decedent not more than 

$1.2 million) from tax on U.S. securities or certain other 

U.S. situs property under the 1995 Protocol to the 

Canadian income tax treaty, do not list the exempt assets 

on Schedule A.

Instead, list those assets and their values in a 

statement attached to the return specifying that you are 

relying on the treaty. To determine initially whether the 

small estate exemption applies, however, you must 

include the exempt assets in the value of the entire gross 

estate, wherever located, on lines 2 and 3 of Schedule B.

United States–United Kingdom Treaty

If a decedent who was a U.K. national, but was neither 

domiciled in nor a national of the United States, has 

property that is subject to U.S. estate tax under the terms 

of the United States–United Kingdom Treaty, the treaty 

places a limit on the amount of U.S. estate tax owed on 

such property. The tax may not exceed the U.S. estate tax 

that could have been imposed on the decedent’s 

worldwide assets had the decedent died domiciled in the 

United States. If the amount of tax on the property 

exceeds that limit, the lower amount may be reported as 

the tax due on the Form 706-NA. You must attach to the 

estate's Form 706-NA a statement showing the alternate 

computation and claiming the benefit of the treaty 

provision. See Paragraph 5 of Article 8 of the treaty.

Schedule B. Taxable Estate

For the line 5 deduction to be allowed, you must 

complete lines 1 through 4 and document the 

amounts you include on lines 2 and 4.

Line 2. The amount on line 2 is the total value of the 

assets included in the entire gross estate that were 

located outside the United States.

To document the line 2 amount, attach a certified copy 

of the foreign death tax return or, if none was filed, a 

certified copy of the estate inventory and the schedule of 

debts and charges that were filed with the foreign probate 

court or as part of the estate's administration proceedings. 

Supplement these documents with attachments if they do 

not set forth the entire gross estate outside the United 

States. If more proof is needed, you will be notified.

If you elected the alternate valuation date for property 

listed on Schedule A, use it also for the assets reported on 

line 2. Otherwise, value the amounts as of the date of 

death.

Line 4. You may deduct the following items whether or 

not they were incurred or paid in the United States.

• Funeral expenses.

• Administration expenses.

• Claims against the estate.

• Unpaid mortgages and liens.

CAUTION

!

• Uncompensated losses that were incurred during 

settlement of the estate and that arose from theft or 

from casualties, such as fires, storms, or shipwrecks.

You may deduct only that part of a debt or mortgage 

that was contracted in good faith and for full value in 

money or money's worth. You may deduct mortgages only 

to the extent of the full value of the mortgaged property 

included in the total gross estate on line 3. Do not deduct 

tax on income received after death or property taxes 

accrued after death. See Line 7, later, for details on 

deducting death taxes.

On line 4, show the total of these deductible items. In 

general, the total is limited to the amount on line 3.

To document the line 4 amount, attach an itemized 

schedule. For each expense or claim, specify the nature 

and amount and give the creditor's name. Describe other 

deductions fully and identify any particular property to 

which they relate.

Line 6. Use line 6 to enter the following deductions.

Charitable deduction. Unless a treaty allows 

otherwise, you may take a charitable deduction only if the 

transfer was to a domestic entity or for use in the United 

States as described in the Instructions for Form 706.

Attach Schedule O of Form 706. If you claim the 

deduction under a treaty, specify the applicable treaty and 

attach a computation of the deduction.

Marital deduction. Unless a treaty allows otherwise, 

you may only take a marital deduction if the surviving 

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

qualified domestic trust (QDOT) described in section 

2056A and an election is made on Schedule M of Form 

706. See Regulations section 20.2056A-2(d) for additional 

QDOT requirements.

Attach Schedule M of Form 706 and a statement 

showing your computation of the marital deduction.

See section 2518 for the rules governing disclaimers of 

interests in property.

Line 7. You may take a deduction on line 7 for death 

taxes (estate, inheritance, legacy, or succession taxes) 

you paid to any state or the District of Columbia on 

property listed in Schedule A. To calculate the deduction 

for state death taxes, use the formula below. Enter the 

result on line 7.

Total value of assets in the gross estate 

subject to state death taxes

x 

Total state death 

Gross estate located in the United States taxes paid

(line 1 of Schedule B)

Generally, you must claim this deduction within 4 years 

of filing the return. However, see section 2058(b) for 

exceptions and periods of limitations.

For the deduction to be allowed, you must file a 

certificate signed by the appropriate official of the taxing 

state. The certificate should show:

• The total tax charged,

• Any discount allowed,

• Any penalties and interest imposed,

• The tax actually paid, and

• Each payment date.

-6- Instructions for Form 706-NA (Rev. 10-2022)
If possible, attach the certificate to this return; 

otherwise, please file it as soon as possible.

If you later recover any of the state tax for which you 

claim this deduction, you must notify the IRS at the 

following address within 30 days of receiving any refund 

of state taxes.

Department of the Treasury

Internal Revenue Service Center

Kansas City, MO 64999

Part II. Tax Computation

Lines 4 and 5. To determine the tentative tax on the 

amount on line 2 (to be entered on line 5) and the tentative 

tax on the amount on line 3 (to be entered on line 4), use 

Table A—Unified Rate Schedule in the version of the 

Instructions for Form 706 that corresponds to the 

decedent's date of death.

Line 7. Enter the unified credit. The unified credit is 

allowed for the smaller of the line 6 amount or the 

maximum unified credit. In general, the maximum unified 

credit is $13,000.

For a citizen of a U.S. possession (see section 2209), 

the maximum unified credit is the greater of:

• $13,000, or

• The product of $46,800 times a fraction.

The numerator of the fraction is the part of the gross 

estate located in the United States (line 1 of Schedule B), 

and the denominator is the entire gross estate wherever 

located (line 3 of Schedule B).

If the unified credit is affected by a treaty, see section 

2102(b)(3)(A).

Note. At the time this form went to print, treaties with 

Australia, Canada, Finland, France, Germany, Greece, 

Italy, Japan, and Switzerland contained provisions to 

which section 2102(b)(3)(A) applies.

Any amount previously allowed as a unified credit 

against the gift tax will reduce, dollar for dollar, the 

unified credit allowed the estate (section 2102(b)

(3)(B)).

Line 9. Use line 9 to enter the following credits.

Credit for federal gift taxes. See sections 2102 and 

2012. Attach computation of credit.

Canadian marital credit. In addition to the unified 

credit, a nonrefundable marital credit may be allowed if 

the executor elects this treaty benefit and waives the 

benefit of any estate tax marital deduction allowable under 

U.S. law. The credit amount is generally limited to the 

lesser of:

• The unified credit allowed to the estate (before 

reduction for any gift tax unified credit), or

• The amount of estate tax that would otherwise be 

imposed by the United States on the transfer of 

qualifying property to the surviving spouse.

See the 1995 Canadian income tax treaty protocol for 

details on computing the credit. Also, attach a 

computation of the credit, and on the dotted line to the left 

of the line 9 entry, enter “Canadian marital credit.”

CAUTION

!

Line 13. If you answered “Yes” to question 11 of Part III, 

you must complete and attach Schedules R and/or R-1 

from Form 706.

For the purposes of Form 706-NA, the GST tax is 

imposed only on transfers of interests in property that are 

part of the gross estate in the United States. Therefore, 

when completing Schedules R and/or R-1, you should 

enter only transfers of interests in property that you listed 

on Schedule A of Form 706-NA. Otherwise, complete 

Schedules R and/or R-1 according to their instructions 

and enter the total GST tax from Schedule R on line 13.

For details, see Regulations section 26.2663-2.

Line 15. Attach an explanation if earlier payments were 

made to the IRS.

Line 16. Pay the balance due within 9 months after the 

decedent's death unless an extension of time to pay was 

granted. Make the check or money order payable to 

“United States Treasury” for the face value in U.S. dollars.

No checks of $100 million or more accepted. The 

IRS cannot accept a single check (including a cashier's 

check) for amounts of $100,000,000 ($100 million) or 

more. If you're sending $100 million or more by check, 

you'll need to spread the payments over two or more 

checks, with each check made out for an amount less 

than $100 million. The $100 million or more amount limit 

does not apply to other methods of payment (such as 

electronic payments).

Signature(s)

If there is more than one executor, all listed 

executors are responsible for the return. However, 

it is sufficient for only one of the co-executors to 

sign the return.

Form 706-NA must be signed. The executor must verify 

and sign the declaration on page 1 under penalties of 

perjury. The executor may use Form 2848 to authorize 

another person to act for the executor before the IRS. See 

the instructions for the authorization in Part III. General 

Information, earlier, or the Instructions for Form 2848 and 

Circular 230, Regulations Governing Practice before the 

Internal Revenue Service, section 10.7(c)(1)(vii), for 

information on representing a person or entity located 

outside the United States.

Third-party designee. If you want to allow the return 

preparer (listed on the bottom of page 1 of Form 706-NA) 

to discuss your Form 706-NA with the IRS, check the 

"Yes" box to the far right of your signature on page 1 of 

your return. If you check the "Yes" box, you are 

authorizing the IRS to call your return preparer to answer 

questions that may arise during the processing of your 

return. You are also authorizing the return preparer of your 

Form 706-NA to:

• Give the IRS any information that is missing from your 

return;

• Call the IRS for information about the processing of 

your return or the status of your payment(s);

• Receive copies of notices or transcripts related to your 

return, upon request; and

• Respond to certain IRS notices about math errors, 

offsets, and return preparation.

CAUTION

!

Instructions for Form 706-NA (Rev. 10-2022) -7-
You are not authorizing your return preparer to receive 

any refund check, to bind you to anything (including any 

additional tax liability), or otherwise represent you before 

the IRS. If you want to expand the authorization of your 

return preparer, see Pub. 947, Practice Before the IRS 

and Power of Attorney. The authorization will 

automatically end 3 years from the date of filing Form 

706-NA. If you wish to revoke the authorization before it 

ends, see Pub. 947.

Generally, anyone who is paid to prepare the return 

must sign the return in the space provided and fill in the 

Paid Preparer Use Only area. See section 7701(a)(36)(B) 

for exceptions.

In addition to signing and completing the required 

information, the paid preparer must give a copy of the 

completed return to the executor.

Note. A paid preparer may sign original or amended 

returns by rubber stamp, mechanical device, or computer 

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 to provide this information.

You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act 

unless the form displays a valid OMB control number. Books or records relating to a form or its instructions must be 

retained as long as their contents may become material in the administration of any Internal Revenue law. Generally, tax 

returns and return information are confidential as required by section 6103. However, section 6103 allows or requires the 

Internal Revenue Service to disclose information from this form in certain circumstances. For example, we may disclose 

information to the Department of Justice for civil or criminal litigation, and to cities, states, the District of Columbia, and 

U.S. commonwealths or possessions for use in administering their tax laws. We may also disclose this information to 

other countries under a tax treaty, to federal and state agencies to enforce federal nontax criminal laws, or to federal law 

enforcement and intelligence agencies to combat terrorism. Failure to provide this information, or providing false 

information, may subject you to penalties.

The time needed to complete and file this form will vary depending on individual circumstances. The estimated 

average time is:

Recordkeeping Learning about the law or 

the form

Preparing the form Copying, assembling, and 

sending the form to the IRS

1 hr., 25 min. 52 min. 1 hr., 36 min. 34 min.

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:

Internal Revenue Service

Tax Forms and Publications Division

1111 Constitution Ave. NW, IR-6526

Washington, DC 20224

Although we can't respond individually to each comment received, we do appreciate your feedback and will consider 

your 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.

-8- Instructions for Form 706-NA (Rev. 10-2022)