9. Description of property.—The description of property under schedule
‘A should be such that the property may be readily identified. Descriptions
of stocks should include number of shares, whether common or preferred,
and, if preferred, what issue thereof, par value, quotation at which returned,
exact name of corporation, and, if the stock is unlisted, the post office ad-
dress of the principal business office, the State in which incorporated and
the date of incorporation. If a listed security, state principal exchange upon
which sold. Descriptions of bonds should include number, principal amount,
name of obligor, date of maturity, rate of interest, date or dates on which
interest is payable, series number where there is more than one issue, the
exchange upon which listed, or the principal business office of the corpora-
tion, if unlisted. For the rules to be followed in valuing stocks and bonds,
see the Estate Tax Regulations and the Instructions for Form 706.

Jointly owned property and property held as tenant by the entirety should
be identified as such, and the entire value thereof should be disclosed in
the column of schedule A for description of property. The right to include
less than the full value of the entire property for purposes of the tax
must be supported by proof. See subparagraph (a) of section 6 of these
instructions.

10. Date of valuation of property—Unless election is properly made at
the time the return is filed to adopt the alternate valuation authorized by
section 2032 of the Code, all property must be valued as of the date of the
decedent's death. In such case the information indicated by the columns of
schedule A headed “Alternate valuation date” and “Alternate value in U.S.
dollars” should not be shown, and the space in such columns may be
utilized for descriptive matter.

if the person filing the return elects to adopt the valuation authorized by
section 2032 of the Code, such election must be expressly indicated in the
space provided under schedule A, and the return must be timely filed. If
such election is made, (1) any property distributed, sold, exchanged, or
otherwise disposed of within 6 months after the decedent's death must be
valued as of the date of such distribution, sale, exchange, or other dispo-
sition, whichever first occurs, and (2) any property not distributed, sold,
exchanged, or otherwise disposed of within such 6 month period must be
valued as of the date 6 months after the date of the decedent's death. The
election, if exercised, must be applied to all property included in the gross
estate on the date of the decedent's death. In such case all columns of
schedule A should be completed.

11. Deduction of administration expenses, claims, etc.—Deduction may
be taken of the proportion of the following expenses, claims, etc., that the
value of the part of the gross estate situated in the United States bears to
the value of the entire gross estate wherever situated: (1) funeral expenses;
(2) administration expenses; (3) claims against the estate; (4) unpaid
mortgages and other liens; and (5) losses incurred during the settlement of
the estate arising from fires, storms, shipwrecks, or other casualties, or
from theft, if such losses are not compensated for by insurance or
otherwise.

It is immaterial whether the amounts to be deducted were incurred or
expended within or without the United States. However, no deduction what-
ever may be taken unless the value of the entire gross estate wherever
situated, as described in section 6 of these instructions, is entered at item
3 of schedule B. The entire gross estate must be valued as of the date of
the decedent's death; or, if the alternate valuation is adopted under
schedule A, such alternate valuation must be applied to the entire gross
estate. Adequate proof in support of items 3 and 4 of schedule B must be
submitted; otherwise, this deduction will be disallowed. For this purpose
there should be submitted a certified copy of the foreign death tax return;
or, if no such return was filed, a certified copy of the inventory of the estate,
together with the schedule of debts and charges, filed in conjunction with
the administration proceedings of the estate or with the foreign court of
probate jurisdiction. Additional proof may be required in specific cases.

The total amount of expenses, claims, etc., should be entered as item 4
of schedule B, which entry must be supported by an itemized schedule.
Such schedule should show the exact nature and amount of each expense
or claim as well as the name of the creditor. Other deductions must be
fully described and, if relating to particular property, the property must be
identified. Death taxes, taxes on income received after death, and property
taxes not accrued prior to death are not to any extent deductible. If a claim
against the estate or a mortgage is founded upon a promise or agreement,
the amount included in item 4 must be limited to the extent to which the
liability was contracted bona fide and for an adequate and full considera-
tion in money or money's worth. Deduction may be taken for a mortgage
only if the value of the property undiminished by the amount of indebtedness
secured by the mortgage is included in the entire gross estate wherever
situated. Except as otherwise provided in section 2053 of the Code, the
amount of deductions entered in item 4 must not exceed the value of the
property included in the entire gross estate wherever situated, which is
subject to claims.

12. Charitable, public, and similar gifts and bequests.—Except as pro-
vided otherwise by treaty, a deduction may be taken on line 6 of Schedule

B only if the transfer was to a domestic entity or for use within the United
States as described in section 2106(a)(2) of the Code. For informa‘
relative to the deduction allowable under the Death Tax Conventions with
France and Greece, see the conventions.

13. Exemption—An exemption of $30,000 is authorized for the purpose
of determining the taxable estate, and should be entered at item 7 of sched-
ule B unless the “‘prorated exemption’’ is claimed. An increased exemption,
referred to as the “prorated exemption” is allowable (a) in the case of a
decedent who was a citizen of the United States and who was a resident of
a United States possession, as referred to in the last sentence of instruc:
tion 1, and (b) in cases where the provisions of a death tax convention
apply to the estate of a decedent who was a citizen of or domiciled in
Australia, Norway or Switzerland, a resident of Finland, was domiciled in
France, was a subject of or domiciled in Greece, was a national of or do
ciled in Italy, or in a case where a beneficiary was domiciled in Japan. The
prorated exemption is computed at item 7 of schedule B. This increased
exemption will be disallowed unless the value of the entire gross estate
wherever situated is entered at item 3 of schedule B and supported by ade-
quate proof, as explained in the second paragraph of section 11 of these
instructions.

14. Computation of tax.—Use the following rates unless the decedent
was an “expatriate” within the meaning of section 2107 of the Code. For
“expatriates” use the rates in Form 706, Table A.

| (B) 1 ‘ | Rate of tax on
Taxabl estate | Tax on amount | “excess over
not exceeding | ‘mcotumn (A) | ane aD
Percent

$100,000 0 5
$100,000 500,000 $5,000 10
500,000 1,000,000 45,000 15
1,000,000 | — 2,000,000 120,000 20
2,000,000 —— 320,000 25

15. Credit for estate, inheritance, legacy, or succession taxes paid to a
State, or the District of Columbia.—The States and the District of Columbia
generally impose inheritance or other death taxes. If such taxes are paid
in respect of property included in schedule A, credit therefor may be taken
at item 2 of the ‘Computation of Tax.” The credit cannot exceed an amount
which bears the same ratio to the credit computed using Form 706,
Table B, as the value of the property upon which State death taxes were
paid and which was included in the gross estate bears to the value of
the total gross estate situated in the United States. The credit is also
limited to such taxes as were actually paid and credit therefor claimed
within 4 years after the filing of the return, except as otherwise provided
under special circumstances. For allowance of the credit, a certificate of
the proper officer of the taxing State, showing the information required by
the Estate Tax Regulations, must be submitted. If practicable such certifi-
cate should be filed with the return, but if that is not convenient or possible,
then it should be submitted as soon thereafter as practicable. If credit is
claimed for any State death tax which is subsequently recovered, see sec-
tion 20.2016-1 of the regulations for the notice required within 30 days.

16. Supplemental documents.—if the decedent died testate, a certified
copy of the will must be filed. In the case of closely held or inactive stock
of a corporation, there must be submitted balance sheets, particularly the
one nearest the valuation date, and statements of the net earnings or op-
erating results and dividends paid for each of the five preceding years. Any
other documents, such as appraisal lists, required for an adequate explana-
tion should be filed with the return. Other supplemental documents may be
required as explained in sections 11, 13, and 17 of these instructions. An
English translation should be submitted with all foreign supplemental
documents.

17. Former United States citizens.—If the answer to question 6 on page
1, is “Yes,” but it is contended that tax avoidance was not one of the prin-
cipal purposes for the loss of United States citizenship, supplemental docu-
ments to sustain the contention should be submitted with the return. If the
loss of United States citizenship was for a principal purpose of tax avoid-
ance, the special tax computation rules in section 2107 of the Code will
apply; in addition, a proportion of the value of stock in certain foreign
corporations described therein which was owned or transferred by the de-
cedent may be required to be included in the gross estate if the foreign
corporation owned assets situated in the United States.

18. Declarations.—if there is more than one executor or administrator,
all should verify and sign the return. If the return is prepared by an attorney
or agent for the person or persons filing the return, the return must also
be signed by such attorney or agent.

U.S. GOVERNMENT PRINTING OFFICE:1971—O-333-696


rom LOGNA

(Rev. July 1971)

Department of the Treasury
Internal Revenue Service

United States Estate Tax Return
Estate of nonresident not a citizen of the United States

use only
eived

(All amounts must be expressed in United States dollars)

Decedent's first name and middle initial

| Decedent's last name

Social security number

Date of death Place of death

Citizenship (Nationality)

Residence (domicile) at time of death

Business or occupation

Name of executor, administrator, or person in possession of property

Name of attorney for estate

In
United | Address Address
States
Name of executor, administrator, or person in possession of property | Name of attorney for estate
Outside —
United | Address Address
States

la Did the decedent die testate? .
b Were letters testamentary or of administration granted
for the estate? . .

if granted to persons other than those filing the return,
state names and addresses above.

2 Did the decedent, at the time of his death, own any—

a Real property located in the United States? .
b Stocks of United States corporations?

c Debt obligations of (1) a United States person or (2)
the United States, a State or any political subdivision
thereof, or the District of Columbia? .

d Other property situated in the United States?

3 Was the decedent engaged in business in the United |
States at date of d death? . hee soe

4 Did the decedent at date of death personally or
through an agent have access to a safe * deposit f box

in the United States? :

5 Did the decedent, at the time of his death, ov ‘own | any”

property situated in the United States as a joint tenant

or as a tenant by the entirety with right of survivorship

or with his spouse as community property? .

“|

_No| 6 Did the decedent lose his United States citizenship |
after March 8, 1965, and within 10 years of his death? |
- i}

Did the decedent make any transfer within 3 years
before his death of a value of $1,000 or more, or any
| transfer during his lifetime of a value of $5,000 or
| more, without an adequate and full consideration in
| money or money's worth, any part of which was situ-
| ated in the United States either at the time of trans-

fer or at the time of the decedent's death? . :

If “yes, " attach Schedule G from Form 706.

Were there in existence at the time of the decedent's
death any trusts created by him during his lifetime,
any part of the property of which was situated in the
i United States either when the trust was created or at
the time of the decedent’s death? .

It “yes,” attach Schedule G from Form 706.

Did the decedent, at the time of his death, possess a
general power of appointment over property any part
of which was situated in the United States? .
If “yes,” attach Schedule H from Form 706.

| b Or, at any time, exercise or release such a power? .

If “yes,” attach Schedule H from Form 706.

| (NOTE.—A general power of appointment means any power of ap-
pointment exercisable in favor of the decedent, his estate, his
creditors, or the creditors of his estate, and includes the right of a
beneficiary to appropriate or consume the principal of a trust. See

Estate Tax Regulations for complete definition.)

Computaticn of Tax

Taxable estate (Item 9, Schedule B, or Item 10, Schedule B(2), whichever is applicable)

Part |

1 Gross estate tax (see instruction 14) .
2 Credit for State death taxes (see instruction 15) .

3 Gross estate tax less credit for State death taxes (item 1 minus item 2). This is 5 the net amount payable ‘unless
credit for Federal gift taxes or tax on prior transfers is claimed in Partll. . . . . . . . s

Part

4 Credit for Federal gift taxes (see Instructions for Form 706) .

5 Credit for tax on prior transfers (attach Schedule O from Form 706) .

6 Total of credits under Part II (total of items 4 and 5).
7 Net estate tax payable (item 3 minus item 6) .



SCHEDULE A—Gross Estate in the United States

Is election hereby made to have the gross estate of this decedent (This election cannot be exercised unless it is shown upon the
valued in accordance with values as of a date or dates subsequent to return and the return is timely filed. The information in columns
the decedent's death as authorized by section 2032 of the Internal (c) and (d) should not be furnished unless the reply to this question
RevenueCode?. . . . . . . . + - + O YES 1) NO is “Yes.”)

(a) (b) | (c) (d) j (e)

Item i Alternate Alternate value in | Value at date of death

No. Complete description of property valuation date United States dollars |in United States dollars

1 $ $

(If more space is needed, attach additional sheets of same size)
Total | $ $
SCHEDULE B—Taxable Estate

If the decedent at the time of his death was domiciled in France to $30,000. See section 13 of instructions for circumstances
or Greece or was a subject of Greece, use Supplemental Schedule under which “prorated exemption” will be allowed. If prorated
B(2) instead of Schedule B. The value to be entered for item 2 exemption is claimed under Japanese treaty, the numerator of the
includes real property situated outside of the United States. If fraction set forth in item 7 is the value of the property situated
adequate proof in support of items 2 and 4 is not submitted, in the United States and the subject of tax by both the United
deduction at item 4 will not be allowed. If adequate proof in sup- States and Japan.

port of item 2 is not submitted, deduction at item 7 will be limited

1 Gross estate in the United States (total, schedule A). 2 2 2 2 6 ee ee he ee ee

2 Gross estate outside the United States. ©. 2 6 1 6 6 6 ee ee ee ee ee

3 Total gross estate wherever situated (line 1 plus line 2). 2 2 2 1 ee ee ee ee ee ee LS

4 Amount of funeral expenses, administration expenses, debts of decedent, mortgages and liens, and losses during
administration (attach itemized schedule). . 2. / 6 6 ee et ee eee ee $.

5 Deduction of expenses, claims, etc. (that proportion of line 4 that line 1 bears to line 3)

6 Charitable, public, and similar gifts and bequests (attach Schedule N from Form 706)
7 Exemption of $30,000 (in estates qualifying for ‘‘prorated exemption,” use $30,000 or.
everisthe greater). 2. 6 2 6 6 ee ee ee ee ee ee

line

8 Total deductions (total of lines 5,6,and7) . 6 6 6 ee ee ee ee ee

9 Taxable estate (line 1 minus line 8) . «+ + + + : _ . . .

Under penalties of perjury, | declare that this return, including the additional sheets attached, if any, has been examined by me, and to the best of my
knowledge and belief, is a true, correct, and complete return. It is understood that a complete return requires the listing herein of all the property constituting

the part of the decedent's gross estate (as defined by the Statute) situated in the United States.

iti) (ate)

rator, or attorney (Address) @ate)

signing below)

Declaration by Attorney in United States
I declare that | am (the/one of the attorney(s) listed on page 1 representing the estate and that | am currently qualified to practice

in the State of .....



Instructions

Highlights
1. Form 706NA is due 9 months after death.

2. Netherlands treaty is in effect,

1. General.—The United States estate tax is imposed by chapter 11 of
the Internal Revenue Code. It is imposed upon the transfer of the taxable
estate of the decedent and not upon the receipt of any particular legacy,
devise, or distributive share.

The first step in the determination of tax liability in the case of a non-
resident not a citizen of the United States is to ascertain the entire gross
estate wherever situated. The second step is to determine the part of such
gross estate situated in the United States, which should be set forth in
schedule A. The third step is to determine the amount of the deductions
authorized, which should be entered as item 8 of schedule B and subtracted
from the part of the gross estate situated in the United States in order to
arrive at the taxable estate. The fourth step is to compute the tax and any
allowable credit.

Reference to the deceased person's residence generally means the de-
ceased person's domicile, and the expression nonresident not a citizen of
the United States refers to a decedent who at the time of his death was
neither domiciled in nor a citizen of the United States and to a decedent
who acquired United States citizenship solely by reason of his connection
with a United States possession.

2. Requirement of return.—Form 706NA must be filed for the estate of
a nonresident not a citizen of the United States if the part of his gross
estate (as defined by the Estate Tax Statute) situated in the United States
exceeded a value of $30,000 at date of death.

If there is no executor or administrator appointed, qualified, and acting
in the United States, every person in actual or constructive possession of
any property of the decedent is liable for the filing of the return. If two or
more persons are liable for the filing of the return, it is preferable for all to
join in the filing of one complete return, but if they are unable to join in
making one complete return, each is required to file a return disclosing all
the information he has in the case, including the name of every person
holding an interest in the property and a full description of such property.

3. Time and place for filing return.—For estates of decedents dying on
or before December 31, 1970, the return is due 15 months after the date
of the decedent’s death. For estates of decedents dying after December 31,
1970, the return is due 9 months after the date of the decedent's death. The
return must be filed with the Director of International Operations, Internal
Revenue Service, Washington, D.C. 20225.

4. Payment of tax.—For estates of decedents dying on or before Decem-
ber 31, 1970, the tax is due 15 months after the date of the decedent's
death, and must be paid within such period unless an extension of time
for payment has been granted by the Director. For estates of decedents
dying after December 31, 1970, the tax is due 9 months after the date
of death except for the extension stated in the preceding sentence. Make
check or money order payable to the Internal Revenue Service and collectible
in U.S. currency at par without any deduction for exchange or other charges.
Section 6651 provides for additions to the tax for both delinquent returns
and for delinquent payments of tax unless due to reasonable cause.

5. Penalties.—The law provides penalties for willful failure to make and
file a return on time and for willful attempt to evade or defeat payment of
tax,

6. Entire gross estate wherever situated—The entire gross estate wher-
ever situated in the case of a nonresident not a citizen of the United States
is made up in the same way as the gross estate of a citizen or resident and
includes real property situated outside of the United States. The gross
estate embraces not only all property beneficially owned by the decedent,
but also includes:

(a) All property in which the decedent had at the time of his death an
interest either as a joint tenant or as a tenant by the entirety, with right of
survivorship. (The full value of the property must be included in the gross
estate, unless it can be shown that a part of the property originally belonged
to the other tenant or tenants and was never received or acquired by the
other tenant or tenants from the decedent for less than an adequate and
full consideration in money or money's worth);

(b) Property held by the decedent and surviving spouse as community
property to the extent of the decedent's interest in such property under the
applicable law of the State, or possession of the United States, or of the
foreign country;

(c) Dower or curtesy of the surviving spouse and all interests created by
statute in lieu thereof;

(d) Proceeds of insurance on the decedent's life, including, with some
exceptions, proceeds receivable by beneficiaries other than the estate;

(e) Several classes of transfers made by the decedent prior to his death,
without an adequate and full consideration in money or money's worth;

(f) Property with respect to which the decedent (1) possessed a general
power of appointment at the time of his death or (2) exercised or released
(in_a specified manner) a general power of appointment during his lifetime;
an

(g) Certain annuities received by a beneficiary by reason of surviving
the decedent.

Further information concerning annuities, life insurance, transfers during
life, and general powers of appointment is set forth in the Estate Tax Regu-
lations and in the Instructions or Form 706.

7. Property situated in the United States.—The part of the gross estate
situated within the United States should be listed in schedule A. The term
“United States,” when used in a geographical sense, includes only the
States, and the District of Columbia. Property transferred during the de
cedent's life, and includible in the entire gross estate wherever situated, is
deemed situated within the United States if such property was so situated
either at the time of the transfer or at the time of death.

Except as provided otherwise by treaty, the following rules are applicable
in determining whether property is situated in the United States:

(a) Real estate and tangible personal property are within the U.S. if
physically located therein.

(b) Irrespective of where the stock certificates are physically located, (1)
stocks of corporations organized in or under the laws of the U.S. constitute
property within the U.S., and (2) stocks of all other corporations constitute
property outside the U.S.

(c) Debt obligations (not otherwise covered in paragraph (e)) of (1) a
United States person (see section 7701(a)(30)), or (2) the United States,
a State or any political subdivision, or the District of Columbia, shall be
deemed property within the United States, whether or not the written
evidence thereof is treated as being the property itself. However, if such
United States person is a domestic corporation with less than 20 percent of
its gross income from all sources derived from sources within the United
States for the 3 taxable years which preceded the date of the decedent's
death, the debt obligation shall be deemed property without the United
States.

(d) Proceeds of insurance on the life of a nonresident not a citizen of the
U.S. decedent are not situated within the U.S.

(e) For estates of decedents dying before January 1, 1976, amounts not
effectively connected with the conduct of a trade or business within the
United States by the decedent (1) deposited with domestic persons carrying
on the banking business, (2) deposited with a domestic savings and joan
or similar association covered by section 591 of the Code, or (3) held by a
domestic insurance company under an agreement to pay interest thereon,
shall be deemed to be property without the United States. For estates of
decedents dying after December 31, 1975, the three preceding amounts
shall be deemed property within the United States. For estates of decedents
dying after December 31, 1969, deposits with a domestic branch of a foreign
corporation, if such branch is engaged in the commercial banking business,
shall be deemed property within the United States. Deposits with a foreign
branch of a domestic corporation or domestic partnership, if such branch
is engaged in the commercial banking business, shall be deemed property
without the United States.

(f) For situs of works of art, owned by a nonresident not a citizen of the
U.S., which were imported into the U.S. for exhibition purposes, see Estate
Tax Regulations.

8. Death duty conventions are in effect with each of the countries listed
below. The provisions of a convention apply in the case of a decedent
dying on or after the effective date shown.

Country Effective Date
Australia January 7, 1954
Canada January 1, 195
Finland wa December 18, 1952
France 2121122122.022... October 17, 1949.
*Greece |: fi ii.i.. December 30, 1953
Ireland 2221.20.) +++: December 20, 1951
Italy aooen October 26, 1956.
Japan April 1, 1955
Netherlands » February 3, 1971
Norway . . December 11, 1951
Switzerland . : September 17, 1952

Union of South Af
United Kingdom .

July 15, 1952

. July 25, 1946

*Section 6 of the instructions governs real property.

If the decedent was a domiciliary or citizen of the Netherlands (and not
a domiciliary or citizen of the United States), only real property and certain
directly owned business assets situated in the United States are deemed
property situated within the United States for purposes of the taxable estate.
However, for tax return reporting purposes, the United States situs rules
determine whether a return must be filed (over $30,000 in the United States)
and the items which must be reported. For example, if the decedent owned
stocks and bonds which under the United States situs rules would be
deemed situated in the United States, they should be reported in sched-
ule A but marked “exempt—Netherlands treaty,” and their total value
should not be included in the amount entered at item 1 of schedule B;
their total value should, however, be included in the amount entered at
item 2 of schedule B. The convention contains detailed rules for deter-
mining domicile.