stocks and bonds, see the Estate Tax Regulations
and the Instructions for Form 706.

Jointly owned property and property held as
* tenants by the entirety should be identified as
such, and the entire value thereof should be dis-
closed 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 col-
umns 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 re-
turn 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 disposi-
tion, whichever first occurs, and (2) any property
not distributed, sold, exchanged, or otherwise dis-
posed 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 pro-
portion 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 en-
tire 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 settle-
ment of the estate arising from fires, storms, ship-
wrecks, 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 de-
ducted were incurred or expended within or with-
out the United States. However, no deduction
whatever 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 sub-
mitted 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 con-
junction with the administration Proceedings of
the estate or with the foreign court of probate
jurisdication. 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 prop-
erty, the property must be identified. Death taxes,
taxes on income received after death, and prop-
erty taxes not accrued prior to death are not to
any extent deductible. If a claim against the es-
tate 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 con-
tracted bona fide and for an adequate and full
consideration in money or money's worth. Deduc-
tion 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.

If a marital deduction is claimed under the
United States-France Death Tax Convention for the
estate of a decedent who was domiciled in France
at the time of his death, include the amount in
the total entered on line 4 of Schedule B and
attach Schedule M from Form 706 together with
an attached sheet showing the computation of the
amount of the marital deduction.

12. Charitable, public, and similar gifts and be-
quests.—Except as provided 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. If a charitable
deduction is claimed under the United States-
France Death Tax Convention or under the United
States-Greece Death Tax Convention for the estate
of a decedent who at the time of his death was
domiciled in France or Greece or was a subject
of Greece, attach Schedule N from Form 706 to-
gether with an attached sheet showing the com-
putation of the amount of the charitable deduction.

13. Exemption.—An exemption of $30,000 is
authorized for the purpose of determining the tax-
able estate, and should be entered at item 7 of
Schedule 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
instruction 1, and (b) in cases where the provi-
sions 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 domi-
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 en-
tered at item 3 of Schedule B and supported by
adequate proof, as explained in the second para-
graph 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 Table A in the
Instructions for Form 706.

U.S. GOVERNMENT PRINTING OFFICE : 197~O-500-296

w | OF I . Pate ot tax on
faxable Tax on amount | excess over
Taxable estate | estate not jin covumn @) | amount in
equaling | exceeding — column (A)
Percent
9} $100,000 9 5
$100,000 | "500,000 | $5,000 10
‘500,000 15
1,000, 20
2,000,000 |... 23

15. Credit for estate, inheritance, legacy, or
succession taxes paid to a State, or the District
of Columbia.—The States and the District of Co-
lumbia 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
Table B in the Instructions for Form 706 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 pro-
vided 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 certificate should be filed with
the return, but if that is not convenient or possi-
ble, then it should be submitted as soon there-
after as practicable. If credit is claimed for any
State death tax which is subsequently recovered,
see section 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 bal-
ance sheets, particularly the one nearest the
valuation date, and statements of the net earn-
ings or operating results and dividends paid for
each of the five preceding years. Any other docu-
ments, such as appraisal lists, required for an
adequate explanation 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 an-
swer to question 6 on page 1, is “Yes,”’ but It is
contended that tax avoidance was not one of the
principal purposes for the loss of United States
citizenship, supplemental documents to sustain
the contention should be submitted with the re-
turn. if the loss of United States citizenship was
for a principal purpose of tax avoidance, the spe-
cial tax computation rules in section 2107 of the
Code will apply; in addition, a proportion of the
value of stock in certain foreign corporations de-
scribed therein which was owned or transferred
by the decedent 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 at-
torney, certified public accountant or agent for
the person or persons filing the return, the re-
turn must also be signed by such attorney, certi-
fied public accountant or agent.


rom TOGNA

(Rev. May 1973)

Department of the Treasury
internal Revenue Service

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

LLR.S. use only
Date received

(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

United
States

Address

Address

Declaration under 26 C.F.R. 601.502(c)(3)(ii) if return prepared by an attorney

| declare that ! am the attorney listed above representing the estate, and that | am currently qualified to practice in the State of __

Wigiiatire of attorney if he prepared the return)

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

Name of attorney for estate

Outside
United | Address Address
States
Yes| No| 6 Did the decedent lose his United States citizenship | Yes |_No
after March 8, 1965, and within 10 years of his death? |"~
la Did the decedent die testate?. . . 2

Were leters testamentary or of administration sranted
forthe estate?. . _

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

ov

2 Did the decedent, at the time of his death, own any—
Real property located in the United States?. . .
Stocks of United States corporations?

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? .

oo

°

7 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? . woe
If “yes,” attach Schedule G from Form 706.

8 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
United States either when the trust was created or at
the time of the decedent’s death?. . . . .

If “yes,” attach Schedule G from Form 706,

3 Was the decedent engaged in business in the United
States atdate ofdeath?. . . 2. . 2. - ee

4 Did the decedent at date of death personally -or
through an agent have access to a safe deposit t box
in the United States? . . . 2 we

5 Did the decedent, at the time of his death, own any
property situated in the United States as a joint tenant
or as a tenant by the entirety with right of survivorship
er with his spouse as community property? .

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

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

9a

os

(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.)

~ Computation of Tax

Taxable estate (Item 9,ScheduleB) . . . . «

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

Part |

3 Gross estate tax less credit for State death taxes (item 1 minus item 2). This is the net amount t payable unless

credit for Federal gift taxes or tax on prior transfers is claimed in Parti}. «© 6. 2 2 2 4 ee ee ee

Part

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

5 Credit for tax on prior transfers (Attach Schedule P 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 Estat

Is election hereby made to have the gross estate of this decedent
valued in accordance with values as of a date or dates subsequent to
the decedent's death as authorized by section 2032 of the Internal

the United States

(This election cannot be exercised unless it is shown upon the
return and the return is timely filed. The information in columns
(c) and (d) should not be furnished unless the reply to this question

Revenue Code? . . . . . YES O NO is “Yes."")
@) () ©) ® ©)
em Complete description of property Alternate Alternate value in | Value at date of death
7 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

The value to be entered for item 2 includes real property situated
outside of the United States. If adequate proof in support of items
2 and 4 is not submitted, deduction at item 4 will not be allowed.
If adequate proof in support of item 2 is not submitted, deduction
at item 7 will be limited to $30,000. See section 13 of instructions

for circumstances under which “prorated exemption” will be al-
lowed. If prorated exemption is claimed under the Japanese treaty,
the numerator of the fraction set forth in item 7 is the value of
the property situated in the United States and the subject of tax
by both the United States and Japan.

1 Gross estate in the United States (total, ScheduleA) . . . .
2 Gross estate outside the United States. . . . . . .

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

4 Amount of funeral expenses, administration expenses, debts of decedent, mortgages and liens, and losses during

administration (Attach itemized schedule.) . . . 2. 1

5 Deduction of expenses, claims, etc. (that proportion of line 4 that line 1 bears to line3) . . . . . .

6 Charitable, public, and similar gifts and bequests (Attach Schedule N from Form 706.). . . . . « .

ine 1

$60,000, which-

7 Exemption of $30,000 (in estates qualifying for ‘prorated exemption,” use $30,000 Orme aX

ever isthe greater). 2 6 6 1 we we ee we ee ee sone sone a
8 Total deductions (total of lines5,6,and7). . . 2. 1. 1 ew we ee ee we ee we
9 Taxable estate (line 1 minus line 8)... . . : os se

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

y the Statute) situated in the United States.

ate)

(Date)



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 dis-
tributive share.

The first step in the determination of tax liabil-
ity in the case of a nonresident 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 deceased 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 citi-
zen 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 ap-
pointed, 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 com-
plete 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.—The
return is due 9 months after the date of the de-
cedent’s death. The return must be filed with the
Internal Revenue Service Center, 11601 Roosevelt
Boulevard, Philadelphia, Pennsylvania 19155.

4. Payment of tax.—The tax is due 9 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. Make check or
money order payable to the Internal Revenue Serv-
ice and collectible in U.S. currency at par without
any deduction for exchange or other charges.

5. Penalties.—Section 6651 provides for addl-
tions to the tax for both delinquent returns and
for delinquent payments of tax unless due to
reasonable cause. The law also 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 wherever 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 oron-

Instructions

it can be shown that a part of the property orig-
inally 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 ade-
quate 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;

(a) Proceeds of insurance on the decedent's
life, including, with some exceptions, proceeds re-
ceivable 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 ap-
pointment during his lifetime; and

(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 Regulations and in the Instructions for 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. con-
stitute property within the U.S., and (2) stocks of
all other corporations constitute property outside
the US.

(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 do-
mestic corporation with less than 20 percent of
its gross income from all sources derived from
sources within the United States for the 3 tax-
able years which preceded the date of the dece-
dent's death, the debt obligation shall be deemed
property without the United States. Certain debt
obligations subject to the interest equalization
tax may be treated as situated outside the United
States for the estate of a decedent dying on or
after January 1, 1973, except that such type obli-
gations of a foreign subsidiary assumed by a
domestic parent during or after the calendar year
1973 may be so treated for the estate of a dece-
dent dying on or after January 1, 1974; for addi-
tional information, see section 2104(c) of the
Code and section 3(a) of Public Law 93-17.

(a) Proceeds of insurance on the life of a non-
resident not a citizen of the U.S. decedent are not

(©) For estates of decedents dying before Jan-
uary 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 busi-
ness (including a domestic banking branch of a
foreign corporation), (2) deposited with a domestic
savings and loan or similar association covered by
section 591 of the Code, or (3) held by a domestic
insurance company under an agreement to pay in-
terest thereon, shall be deemed to be property
without the United States. For estates of decedents
dying after December 31, 1975, the three preced-
ing amounts 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 bank
ing business, shall be deemed property without
the United States.

()) For situs of works of art, owned by a non-
resident not a citizen of the U.S., which were im
ported 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, 1959
Finland ....... December 18, 1952
France . October 17, 1949
"Greece . December 30, 1953

freland .. December 20, 1951
Italy . October 26, 1956
Japan .. April 1, 1955
Netherlands . February 3, 1971
Norway . December 11, 1951
Switzerland . .. September 17, 1952
Union of South Africa ... July 15, 1952
United Kingdom . . . duly 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 cer-
tain directly owned business assets situated in the
United States are deemed property situated within
the United States for purposes of the taxable es-
tate. 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 Schedule A but marked
“exempt—Netherlands treaty,” and their total
value should not be included in the amount en-
tered at item 1 of Schedule B; their total value
should, however, be included in the amount en-
tered at item 2 of Schedue B. The convention con-
tains detailed rules for determining domicile.

9. Description of property.—The description of
property under Schedule A should be such that
the property may be readily identified. Descrip-
tion of stocks should include number of shares,
whether common or preferred, and, if preferred,
what issue thereof, par value where needed for
identification, quotation at which returned, exact
name of corporation, and, if the stock is unlisted,
the post office address 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. Description
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 corporation, if un-