Instructions for

Form 706-GS(D-1)

(Rev. November 2021)

Use with the October 2008 revision of Form 706-GS(D-1)

Notification of Distribution From a Generation-Skipping Trust

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-GS(D-1) and its instructions, such 

as legislation enacted after they were 

published, go to IRS.gov/Form706-

GS(D-1).

General Instructions

Purpose of Form

A trustee uses Form 706-GS(D-1) to 

report certain distributions from a trust 

that are subject to the generationskipping transfer (GST) tax and to 

provide the skip person distributee with 

information needed to figure the tax due 

on the distribution.

Who Must File

In general, the trustee of any trust that 

makes a taxable distribution must file a 

Form 706-GS(D-1) for each skip 

person. See Distributions Subject to 

GST Tax, later, for a discussion of what 

constitutes a taxable distribution. The 

trustee must file a return for each skip 

person even if the inclusion ratio 

applicable to the distribution is zero. 

See Column d. Inclusion Ratio.

When to File

The trustee must file Copy A of Form 

706-GS(D-1) with the IRS and send 

Copy B to the distributee by April 15th of 

the year following the calendar year 

when the distribution was made. If the 

due date falls on a Saturday, Sunday, or 

legal holiday, file on the next business 

day.

Where To File

The trustee must send Copy A of Form 

706-GS(D-1) to the following address:

Department of the Treasury

Internal Revenue Service Center

Stop 824G

7940 Kentucky Drive

Florence, KY 41042-2915

Trusts

Nonexplicit trusts. An arrangement 

that has substantially the same effect as 

a trust will be treated as a trust even 

though it is not an explicit trust. 

Examples of such arrangements are 

insurance and annuity contracts, 

arrangements involving life estates and 

remainders, and estates for years.

In general, a transfer of property in 

which the identity of the transferee is 

conditioned on the occurrence of an 

event is a transfer in trust. However, this 

rule does not apply to a testamentary 

trust if the event is to occur within 6 

months of the transferor's date of death.

Nonexplicit trusts do not include 

decedents' estates.

In the case of a nonexplicit trust, the 

person in actual or constructive 

possession of the property involved is 

considered the trustee and is liable for 

filing Form 706-GS(D-1).

If you are filing this return for a 

nonexplicit trust, see Line 2a. Trust's 

Employer Identification Number.

Separate trusts. You must treat the 

following as separate trusts:

• Portions of a trust that are attributable 

to transfers from different transferors 

and

• Substantially separate and 

independent shares of different 

beneficiaries in a trust.

You must report such separate trusts 

under different item numbers in column 

a of line 3, even if they have the same 

inclusion ratios.

Distributions Subject to 

GST Tax

In general, all taxable distributions are 

subject to the GST tax. A taxable 

distribution is any distribution from a 

trust to a skip person (other than a 

taxable termination or a direct skip).

If any GST tax imposed on a 

distribution is paid out of the trust from 

which the distribution was made, the 

amount of tax paid by the trust is also a 

taxable distribution.

A distribution is not considered a 

taxable distribution if, had it been made 

while an individual was alive, it would 

have been a nontaxable gift because of 

section 2503(e) (relating to transfers 

made for certain educational or medical 

expenses).

Also, a distribution (or any portion 

thereof) is not a taxable distribution to 

the extent that:

• The property distributed was 

previously subject to GST tax and

• The distributee in the prior distribution 

is assigned to a generation the same as 

or lower than the distributee in the 

current distribution.

This rule does not apply if the 

transfers have the effect of avoiding 

GST tax for any transfer.

Exceptions

Irrevocable trusts. The GST tax does 

not apply to any distribution from a trust 

that was irrevocable on September 25, 

1985. Any trust in existence on 

September 25, 1985, will be considered 

irrevocable unless:

• On September 25, 1985, the value of 

the trust could have been included in 

the settlor's gross estate for federal 

estate tax purposes by reason of 

section 2038 if the settlor had died on 

September 25, 1985, or

• Regarding a policy of life insurance 

that is treated as a trust under section 

2652(b), the insured was an owner on 

September 25, 1985, and this would 

have caused the insurance proceeds to 

be included in the insured's gross estate 

for federal estate tax purposes if the 

insured had died on September 25, 

1985.

For more information, see 

Regulations section 26.2601-1(b).

Trusts containing qualified terminable interest property. If an irrevocable 

trust in existence on September 25, 

1985, holds qualified terminable interest 

property (QTIP) (as defined in section 

2056(b)(7)) as a result of an election 

under section 2056(b)(7) or 2523(f), the 

trust may elect to be treated for 

purposes of the GST tax as if the QTIP 

Sep 09, 2021 Cat. No. 10926L
election had not been made. Thus, 

transfers from such a trust will not be 

subject to the GST tax.

Additions to irrevocable trusts. To 

the extent that a distribution from a trust 

is from an addition to an irrevocable 

trust made after September 25, 1985, 

such distribution is subject to the GST 

tax. Additions include constructive 

additions described in Regulations 

section 26.2601-1(b)(1)(v).

For purposes of figuring the inclusion 

ratio (defined later), use only the value 

of the total additions made to the trust 

after September 25, 1985.

Distributions from trusts to which 

additions have been made. As 

described earlier, when an addition is 

made after September 25, 1985, to an 

irrevocable trust, only the portion of the 

trust resulting from the addition is 

subject to the GST tax. For distributions, 

this portion is the product of the 

allocation fraction and the value of the 

property distributed (including 

accumulated income and appreciation 

on that property).

The allocation fraction is a fraction, 

the numerator of which is the value of 

the addition as of the date it was made 

(regardless of whether it was subject to 

gift or estate tax, but reduced by the 

amount of federal or state estate or gift 

tax imposed and paid by the trust). The 

denominator of the fraction is the fair 

market value of the entire trust 

immediately after the addition, less any 

trust amount that is similar to expenses, 

indebtedness, or taxes that would be 

allowable as a deduction under section 

2053, and further reduced by the same 

amount that the numerator was reduced 

by to reflect federal or state estate or gift 

taxes paid by the trust.

When there is more than one 

addition, the allocation fraction is 

revised after each addition. The 

numerator of the revised fraction is the 

sum of:

1. The value of the trust subject to 

the GST tax immediately before the last 

addition and

2. The amount of the latest addition.

The denominator of the revised 

fraction is the total value of the entire 

trust immediately after the latest 

addition. If the addition results from a 

generation-skipping transfer, reduce the 

numerator and denominator by the 

amount of any GST tax imposed on the 

transfer and recovered from the trust. 

Round off the allocation fraction to five 

decimal places (for example, 

“0.00001”).

Transition Rule for Revocable 

Trusts

The GST tax will not apply to any 

distributions from a revocable trust, 

provided:

1. The trust was executed before 

October 22, 1986;

2. The trust as it existed on October 

21, 1986, was not amended after 

October 21, 1986, in any way that 

created or increased the amount of a 

generation-skipping transfer;

3. Except as provided later, no 

addition was made to the trust; and

4. The settlor died before January 1, 

1987.

A revocable trust is any trust that on 

October 22, 1986, was not an 

irrevocable trust (as defined earlier) and 

would not have been an irrevocable 

trust had it been created before 

September 25, 1985.

The instructions under Trusts 

containing qualified terminable interest 

property apply also to revocable trusts 

covered by these transition rules.

Amendments to revocable trusts. An 

amendment to a revocable trust in 

existence on October 21, 1986, will not 

be considered to result in the creation of 

or an increase in the amount of a 

generation-skipping transfer where:

• The amendment is administrative or 

clarifying in nature; or

• It is designed to perfect a marital or 

charitable deduction for an existing 

transfer, and it only incidentally 

increases the amount transferred to a 

skip person.

Addition to revocable trusts. If an 

addition (including a constructive 

addition) to a revocable trust is made 

after October 21, 1986, and before the 

death of the settlor, all subsequent 

distributions from the trust will be 

subject to the GST tax, provided the 

other requirements of taxability are met. 

For settlors dying before January 1, 

1987, any addition made to a revocable 

trust after the death of the settlor will be 

treated as if made to an irrevocable 

trust.

See Regulations section 

26.2601-1(b)(2)(vii) for examples 

demonstrating the operation of these 

rules.

Transition Rule in Case of 

Mental Disability

If the settlor was under a disability on 

October 22, 1986, the GST tax may not 

apply. See Regulations section 

26.2601-1(b)(3) for a definition of the 

term “mental disability” and details on 

the application of this rule.

Exceptions to Additions Rule

Do not treat as an addition to a trust any 

addition that is made pursuant to an 

instrument or arrangement that is 

covered by the rules discussed earlier 

under Transition Rule for Revocable 

Trusts and Transition Rule in Case of 

Mental Disability. This also applies to 

inter vivos transfers if the same property 

would have been added to the trust by 

such an instrument. For examples 

illustrating this rule, see Regulations 

section 26.2601-1(b)(4)(ii).

Definitions

Skip persons. For GST tax purposes, 

skip person means:

1. A natural person assigned to a 

generation that is two or more 

generations below the settlor's 

generation, or

2. A trust that meets the following 

conditions:

a. All interests in the trust are held 

by skip persons, or

b. No person holds an interest in the 

trust, and at no time after the transfer to 

the trust may a distribution be made to a 

non-skip person.

Non-skip person. A non-skip person is 

any person who is not a skip person.

Generation assignment. A generation 

is determined along family lines as 

follows:

1. Where the beneficiary is a lineal 

descendant of a grandparent of the 

transferor (for example, the donor's 

cousin, niece, nephew, etc.), the 

number of generations between the 

transferor and the descendant is 

determined by subtracting the number 

of generations between the grandparent 

and the transferor from the number of 

generations between the grandparent 

and the descendant.

2. Where the beneficiary is the lineal 

descendant of a grandparent of a 

spouse (or former spouse) of the 

transferor, the number of generations 

between the transferor and the 

descendant is determined by 

subtracting the number of generations 

between the grandparent and the 

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spouse (or former spouse) from the 

number of generations between the 

grandparent and the descendant.

3. For this purpose, a relationship 

by adoption is considered a blood 

relationship. A relationship by half-blood 

is considered a relationship by whole 

blood.

4. The spouse or former spouse of a 

transferor or lineal descendant is 

considered to belong to the same 

generation as the transferor or lineal 

descendant, as the case may be.

A person who is not assigned to a 

generation according to the rules above 

is assigned to a generation based on his 

or her birth date as follows.

1. A person who was born not more 

than 121/2 years after the transferor is in 

the transferor's generation.

2. A person born more than 121/2 

years, but not more than 371/2 years, 

after the transferor is in the first 

generation younger than the transferor.

3. Similar rules apply for a new 

generation every 25 years.

If more than one of the rules for 

assigning generations applies to a 

beneficiary, the beneficiary is generally 

assigned to the youngest of the 

generations that apply.

If an entity such as a partnership, 

corporation, trust, or estate has an 

interest in the property, each individual 

who has a beneficial interest in the 

entity is treated as having an interest in 

the property. The individual is then 

assigned to a generation using the rules 

described above.

Governmental entities and certain 

charitable organizations are assigned to 

the transferor's generation. Distributions 

to them will never be 

generation-skipping transfers.

Generation assignment where intervening parent is deceased. If you 

made a gift or bequest to your 

grandchild and at the time you made the 

gift or bequest, the grandchild's parent 

(who is your or your spouse's or your 

former spouse's child) is deceased, 

then for purposes of generation 

assignment, your grandchild will be 

considered to be your child rather than 

your grandchild. Your grandchild's 

children will be treated as your 

grandchildren rather than your 

great-grandchildren.

This rule is also applied to your lineal 

descendants below the level of 

grandchild. For example, if your 

grandchild is deceased, your 

great-grandchildren who are lineal 

descendants of the deceased 

grandchild are considered your 

grandchildren for purposes of the GST 

tax.

This rule also governs generation 

assignment for other lineal 

descendants. For example, if property is 

transferred to an individual who is a 

descendant of a parent of the transferor, 

and that individual's parent (who is a 

lineal descendant of the parent of the 

transferor) is deceased at the time the 

transfer is subject to gift or estate tax, 

then for purposes of generation 

assignment, the individual is treated as 

if he or she is a member of the 

generation that is one generation below 

the lower of:

• The transferor's generation or

• The generation assignment of the 

youngest living ancestor of the 

individual, who is also a descendant of 

the parent of the transferor.

The same rules apply to the 

generation assignment of any 

descendant of the individual.

This rule does not apply to a transfer 

to an individual who is not a lineal 

descendant of the transferor if the 

transferor has any living lineal 

descendants.

If any transfer of property to a trust 

would have been a direct skip except for 

this generation assignment rule, then 

the rule also applies to transfers from 

the trust attributable to such property.

Ninety-day rule. For purposes of 

determining if an individual's parent is 

deceased at the time of a testamentary 

transfer, an individual's parent who dies 

no later than 90 days after a transfer 

occurring by reason of the death of the 

transferor is treated as having 

predeceased the transferor. The 90-day 

rule applies to transfers occurring on or 

after July 18, 2005. See Regulations 

section 26.2651-1 for more information.

Multiple skips. If after a 

generation-skipping transfer the 

property transferred is held in trust, then 

for the purpose of determining the 

taxability of subsequent distributions 

from the trust involving that property, the 

settlor of the property is assigned to the 

first generation above the highest 

generation of any person who has an 

interest in the trust immediately after the 

initial transfer.

Signature

The trustee, or an authorized 

representative of the trustee, must sign 

Form 706-GS(D-1).

If someone prepares your return and 

does not charge you, that person should 

not sign the return. Generally, anyone 

who is paid to prepare your return must 

sign it in the space indicated.

Specific Instructions

Part I—General 

Information

Line 1a. Skip Person 

Distributee's Identifying 

Number

Enter the social security number of an 

individual distributee. (If the number is 

unknown or the individual has no 

number, indicate “unknown” or “none.”) 

If the distributee is a trust, enter the 

trust's employer identification number 

(EIN).

Line 2a. Trust's Employer 

Identification Number

Enter the EIN of the trust from which the 

distribution was made.

A nonexplicit trust as described 

under Who Must File must have an EIN 

that is separate from any other entity's 

EIN and that will be used only by the 

nonexplicit trust.

A trust or nonexplicit trust that does 

not have an EIN should apply for one on 

Form SS-4, Application for Employer 

Identification Number. You can get 

Form SS-4, and other IRS tax forms and 

publications, by visiting IRS.gov/Forms.

Send Form SS-4 to the address 

listed under Where To File. If the EIN 

has not been received by the filing time 

for the GST form, write “Applied for” on

line 2a.

Part II—Distributions

Report all taxable distributions made 

during the year from the trust listed on 

line 2 to the skip person distributee 

listed on line 1. Report a distribution 

even if its inclusion ratio is zero.

Column a. Item No.

Assign consecutive numbers to each 

distribution made during the year. 

Different items of property having 

different inclusion ratios must be listed 

separately in Part II. Include under a 

single item number any properties 

having the same inclusion ratio even if 

they were distributed at different times. 

An exception to this is distributions from 

“separate trusts” as that term was 

defined earlier. You must report 

distributions from such separate trusts 

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under different item numbers even if 

they have the same inclusion ratio.

Column b. Description of 

Property

Real estate. Describe the real estate in 

enough detail so that the IRS can easily 

locate it for inspection and valuation. 

For each parcel of real estate, report the 

location and, if the parcel is improved, 

describe the improvements. For city or 

town property, report the street number, 

ward, subdivision, block and lot, etc. For 

rural property, report the township, 

range, landmarks, etc.

Stocks and bonds. For stocks, give:

• Number of shares;

• Whether common or preferred;

• Issue;

• Par value where needed for 

valuation;

• Price per share;

• Exact name of corporation;

• Principal exchange upon which sold, 

if listed on an exchange; and

• CUSIP number.

For bonds, give:

• Quantity and denomination;

• Name of obligor;

• Date of maturity;

• Interest rate;

• Interest due date;

• Principal exchange, if listed on an 

exchange; and

• CUSIP number.

If the stock or bond is unlisted, show 

the company's principal business office.

The CUSIP (Committee on Uniform 

Security Identification Procedure) 

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 the CUSIP number is not 

printed on the certificate, it may be 

obtained through the company's 

transfer agent.

Other personal property. Any 

personal property distributed must be 

described in enough detail that the IRS 

can value it.

Column d. Inclusion Ratio

Note. The trustee must provide the 

inclusion ratio for every distribution.

All distributions, or any part of a single 

distribution, that have different inclusion 

ratios must be listed as separate items 

in column a.

The inclusion ratio is the excess of 1 

over the applicable fraction determined 

for the trust from which the distribution 

was made.

Applicable fraction. The applicable 

fraction is a fraction, the numerator of 

which is the amount of the GST 

exemption allocated to the trust. The 

denominator of the fraction is:

1. The value of the property 

transferred to the trust, minus

2. The sum of:

a. Any federal estate tax or state 

death tax actually recovered from the 

trust attributable to the property and

b. Any charitable deduction allowed 

under section 2055 or 2522 with respect 

to the property.

Round the applicable fraction to at 

least the nearest one-thousandth (for 

example, “0.001”).

Numerator (GST exemption). Every 

individual settlor is allowed a lifetime 

GST exemption to be allocated against 

property that the individual has 

transferred. For generation-skipping 

transfers made through 1998, the 

exemption was $1 million. The GST 

exemption amounts thereafter are as 

follows:

Year Amount

1999 .............. $1,010,000

2000 .............. $1,030,000

2001 .............. $1,060,000

2002 .............. $1,100,000

2003 .............. $1,120,000

2004 and 2005 ........ $1,500,000

2006–2008 .......... $2,000,000

2009 .............. $3,500,000

2010 and 2011 ........ $5,000,000

2012 .............. $5,120,000

2013 .............. $5,250,000

2014 .............. $5,340,000

2015 .............. $5,430,000

2016 .............. $5,450,000

2017 .............. $5,490,000

2018 .............. $11,180,000

2019 .............. $11,400,000

2020 .............. $11,580,000

2021 .............. $11,700,000

A valid Deceased Spousal 

Unused Exclusion Amount 

(“DSUE ” or portability) election 

by an executor of a deceased spouse's 

estate does not apply to or impact GST 

tax exemption.

For existing trusts, transferors may 

allocate the additional GST exemption 

amount attributable to section 2631(c) 

increases if they otherwise qualify under 

the existing rules for late allocations. For 

more information, see section 2632 and 

Multiple transfers into a trust, later.

CAUTION

!

Once made, allocations are 

irrevocable.

Allocation of the GST exemption is 

made by the settlor on Form 709, United 

States Gift (and Generation-Skipping 

Transfer) Tax Return, and/or Form 706, 

United States Estate (and 

Generation-Skipping Transfer) Tax 

Return, by the executor of the settlor's 

estate. Therefore, you should obtain 

information regarding the allocation of 

the exemption to this trust from the 

settlor or the executor of the settlor's 

estate, as applicable.

If the settlor's entire GST exemption 

is not allocated by the due date 

(including extensions) of the settlor's 

estate tax return, the exemption is 

automatically allocated under the rules 

of section 2632.

Transfers subject to an estate tax inclusion period. If a transferor made an 

inter vivos transfer, and the property 

transferred would have been includible 

in the transferor's estate if he or she had 

died immediately after the transfer 

(other than by reason of the transferor 

dying within 3 years of making the gift), 

for purposes of determining the 

inclusion ratio, an allocation of GST 

exemption will only become effective at 

the close of the estate tax inclusion 

period (ETIP).

The value of the property for the 

purpose of figuring the inclusion ratio is 

the estate tax value if the property is 

included in the transferor's gross estate, 

or its value at the close of the ETIP.

The ETIP closes at the earliest of:

1. The time the transferred property 

would no longer be includible in the 

settlor's estate,

2. The date of a generationskipping transfer of the property, or

3. The date of death of the settlor.

Denominator (valuation of trust assets). In general, the value to be used 

in the applicable fraction is the gift tax 

value for an inter vivos transfer as long 

as the allocation of the GST exemption 

was made on a timely filed gift tax 

return. The value of a testamentary 

transfer is generally the estate tax value.

If the allocation of the exemption to 

an inter vivos transfer, made before 

January 1, 2001, is not made on a 

timely filed gift tax return, the value for 

purposes of the applicable fraction is 

the value of the property transferred at 

the time the allocation is filed with the 

IRS.

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Qualified terminable interest 

property. For qualified terminable 

interest property (QTIP) that is included 

in the estate of the surviving spouse of 

the settlor because of section 2044, 

unless a special QTIP election has been 

made under section 2652(a)(3), the 

surviving spouse is considered the 

transferor under section 2652(a) for 

GST purposes, and the value is the 

estate tax value in the estate of the 

surviving spouse.

A special QTIP election allows 

property for which a QTIP election was 

made for estate or gift tax purposes to 

be treated for GST tax purposes as if 

this QTIP election had not been made. If 

the special QTIP election has been 

made, the predeceased settlor spouse 

is the transferor and the value is that 

spouse's estate or gift tax value under 

the rules described above. Either the 

settlor spouse or the executor of the 

settlor spouse's estate must make the 

special QTIP election.

ETIP. If an individual could not make 

a timely allocation of exemption 

because of an ETIP, the value of the 

property for the purpose of computing 

the inclusion ratio is the estate tax value 

if the property is includible in the 

transferor's gross estate. If the property 

is not includible in the transferor's gross 

estate, the property is valued at the 

close of the ETIP, provided that the GST 

exemption is allocated on a timely filed 

gift tax return for the calendar year in 

which the ETIP closes.

Multiple transfers into a trust. When 

a transfer is made to a pre-existing trust, 

the applicable fraction must be 

recomputed. The numerator of the new 

fraction is the sum of:

1. The exemption allocated to the 

current transfer and

2. The nontax portion of the trust 

immediately before the current transfer 

(the product of the applicable fraction 

and the value of all of the property in the 

trust immediately before the current 

transfer).

The denominator of the new fraction 

is the sum of:

1. The value of the current transfer 

(minus any federal estate tax or state 

death tax actually paid by the trust 

attributable to such property) and any 

charitable deduction allowed with 

respect to such property and

2. The value of all property in the 

trust immediately before the current 

transfer.

Charitable lead annuity trusts. For 

distributions from a charitable lead 

annuity trust, the numerator of the 

applicable fraction is the adjusted GST 

exemption as defined below. The 

denominator is the value of the trust 

immediately after termination of the 

charitable lead annuity.

The adjusted GST exemption is the 

sum of:

1. The exemption allocated to the 

trust and

2. Interest on the exemption 

determined at the interest rate used to 

figure the estate or gift deduction for the 

charitable lead annuity and for the 

actual period of the charitable lead 

annuity.

In the case of a late allocation, the 

amount of interest accrued prior to the 

date of allocation is zero.

Column e. Value

Enter the value of the property 

distributed from the trust at the time of 

distribution.

Part III—Trust Information

Line 4

An arrangement that has substantially 

the same effect as a trust will be treated 

as a trust even though it is not an 

explicit trust. Examples of such 

arrangements are insurance and 

annuity contracts, arrangements 

involving life estates and remainders, 

and estates for years. Nonexplicit trusts 

do not include decedent's estates.

In the case of a nonexplicit trust, the 

trustee is the person in actual or 

constructive possession of the property 

involved.

Line 5

Whenever property is transferred into a 

pre-existing trust, the inclusion ratio 

must be refigured. See Multiple 

transfers into a trust for the rule on how 

to refigure the inclusion ratio.

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 

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administration of any Internal Revenue 

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information are confidential, as required 

by section 6103.

The time needed to complete and file 

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average time is:

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We welcome your comments about 

these instructions and your suggestions 

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comments through IRS.gov/

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the Internal Revenue Service, Tax 

Forms and Publications, 1111 

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