Form 706NA (Rev. 11-81)

Page 4

(3) an amount held by a U.S. insurance
company under an agreement to pay
interest.

(4) 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 these location rules
as of the date of the decedent’s death. How-
ever, if an asset is included in the decedent's
total gross estate under one of the transfer
Provisions (sections 2035, 2036, 2037, and
2038) apply the location rules to the prop-
erty at the time of transfer. For example, if
an item of tangible personal property was
physically located in the U.S. on the date of
a section 2038 transfer, but had been moved
outside the U.S. at the time of the de-
cedent’s death, the item would be consid-
ered still located in the U.S. and should be
listed on Schedule A.

Describe the property on Schedule A in
enough detail to enable IRS to identify it.
To determine the fair market value of stocks
and bonds, use the rules in the Instructions
for Schedule B of Form 706.

In descriptions of stock include: the cor-
poration’s name, the number of shares,
whether common or preferred (if preferred,
what issue), the par value (when needed for
identification), 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, the State
in which incorporated, and the incorporation
date.

In bond descriptions include: the number,
principal, obligor’s name, maturity date, in-
terest rate, each date when interest is pay-
able, and series number (if more than one
issue). Give the exchange where the bond
is listed; if it is unlisted, give the corpora-
tion’s main business office.

Identify all property owned jointly or as
tenants by the entirety, and give the full
value in column (b). If you show less than
the full value in column (d) or (e), you must
document your right to do so.

If the gross estate includes any property
transferred by the decedent within 3 years
before death (section 2035), including
qualified joint tenancies (sections 2040
(b) or (d)) created within 3 years before
death, report these assets on part A of
Schedule G of Form 706. Attach Schedule
G to Form 706NA and enter “Total from
Schedule G, Form 706” to report these as-
sets on Schedule A of Form 706NA, enter-
ing the total value from Schedule G in col-
umns (d) or (e).

If the decedent was a U.S. expatriate, the
decedent is treated as owning a prorated
share of the U.S. property held by a foreign
corporation in which he or she directly owned
at least 10% of the voting stock and, with
related interests, controlled over 50% of it
(section 2107(b))..

Property valuation date.—Generally, prop-
erty must be valued as of the date of death.
Columns (c) and (d) do not apply, and you
may use the space to expand descriptions
from column (b).

However, if you file Form 706NA on time,
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 prop-
erty distributed, sold, exchanged, or other-
wise disposed of within 6 months after the
decedent's death is valued as of the date

of the disposition. Any property not dis-
posed of during that period is valued as of
the date 6 months after the decedent’s
death.

Schedule B.—

For the line 5 deduction to be allowed, you
must complete lines 1-4 and document
the amounts you include on lines 2 and 4.
To document the line 2 amount, attach a
certified copy of the foreign death tax re-
turn; 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 es-
tate’s administration proceedings. If more
proof is needed, you will be notified.

To support 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 de-
ductions fully and identify any particular
property to which they relate.

Line 2.—The amount on line 2 is the total
value of the assets included in the entire
gross estate that were not listed on Schedule
A. If you elected the alternate valuation date
for property listed in Schedule A, use it also
for the assets valued 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 U.S.: funeral expenses; adminis-
tration expenses; claims against the estate;
unpaid mortgages and other liens; and un-
compensated losses that were incurred dur-
ing settlement of the estate and that arose
from theft or from casualties such as fires,
storm, or shipwreck. You may deduct only
that part of a debt or mortgage that was con-
tracted in good faith and for full value in
money or money’s worth. You may deduct
mortgages only if you included the full value
of the mortgaged property in the total gross
estate (line 3). Do not deduct death taxes,
tax on income received after death, or prop-
erty taxes accrued after death.

On line 4 show the total of these deducti-
ble items. In general, the total is limited to
the amount on line 3.

Marital deduction: French domicile
only.—lIf you claim a marital deduction un-
der the U.S.-France Death Tax Convention
for the estate of a person domiciled in
France at the time of death, include the de-
duction on line 4. Attach Schedule M, Form
706, and a statement showing your com-
putation of the marital deduction.

Line 5.—To find your actual deduction,
multiply the line 4 amount by a fraction. The
numerator is the amount on line 1, and the
denominator is the amount on line 3. Enter
the result on line 5.

Line 6.—Unless a treaty allows other-
wise, you may take a charitable deduction
only if the transfer was to a domestic en-
tity or for use in the U.S. as described in
Publication 448. Attach Schedule O of Form
706. If you claim the deduction under the
U.S.-France Death Tax Convention for a de-
cedent domiciled in France, or under the
U.S.-Greece Death Tax Convention for a
decedent domiciled in Greece, or for a Greek
subject, also attach a computation of the
deduction.

See section 2518 for the rules govern-
ing disclaimers of interest in property.

Page 1

Lines 4-5.—Use the following rates un-
less the decedent was a U.S. expatriate. In
that case, use the rates given in Table A of
the Instructions for Form 706.

Mang lee) eae ggeun
$ 100,000 6% 0

500,000 6,000 + 12% $ 100,000
1,000,000 54,000 + 18% 500,000
2,000,000 144,000 + 24% 1,000,000
Over $2,000,000 | 384,000 + 30% 2,000,000

Line 7.—Enter the unified credit. The
unified credit is allowed for the lesser of the
line 6 amount or the maximum unified
credit. In general, the maximum unified
credit is $3,600, but for a U.S. expatriate it
is $13,000. For a citizen of a U.S. posses-
sion (section 2209) who died after 1980 the
maximum unified credit is the greater of
(a) $3,600 or (b) the product of $15,-
075 times a fraction. The numerator of the
fraction is the part of the gross estate lo-
cated in the U.S. (line 1 of Schedule B) and
the denominator is the entire gross estate
wherever located (line 3 of Schedule B). If
the decedent died before 1980 see section
2102(c)(3).

Line 9.—You may take a credit for part
of the death or inheritance taxes you paid
to a State or the District of Columbia on
property listed in Schedule A. Generally, you
must claim this credit within 4 years of filing
the return. To find your allowed credit, first
use Table C in the Form 706 instructions to
figure the supposed credit that would be al-
lowable on the entire line 1 amount (re-
duced by $60,000). Your allowed credit
cannot be more than this supposed credit
multiplied by a fraction. The numerator of
the fraction is.the value of the property you
include in Schedule A and on which you paid
the State tax, and the denominator is the
value of all the property you report in Sched-
ule A. Enter the lesser of this amount or
the taxes you paid on line 9.

For the credit to be allowed, you must file
a certificate signed by the appropriate offi-
cial 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 pay-
ment date. If possible, attach the certificate
to this return; otherwise, please file it as
soon as possible. See Regulations section
20.2011-1(c)(2) for more information about
the certificate.

If you later recover any of the State tax
for which you claim this credit, notify the
Internal Revenue Service Center, Philadel-
phia, PA 19255 within 30 days of receiving
any refund of State taxes.

Lines 15-16.—Attach an explanatory
statement if earlier payments were made to
the Internal Revenue Service or if payment
is made by certain U.S. Treasury bonds that
were issued before March 4, 1971, and re-
deemed at any Federal Reserve Bank, the
office of the Treasurer of the United States,
or the Bureau of Public Debt. For details, see
Rev. Proc. 69-18, 1969-2 C.B. 300.

Line 18.—Pay the balance due within 9
months after the decedent’s death unless an
extension of time to pay was granted. In
that case, attach a copy of the approved
Form 4768 to Form 706NA. Make the check
or money order payable to the Internal Reve-
nue Service for the face value in U.S.
dollars.

Signature.—Form 706NA must be signed.
Each personal representative must verify
and sign it. If another person prepares Form
7O6NA for the personal representative, the
preparer must also sign. The personal rep-
resentative may use Form 2848, Power of
Attorney, to authorize another person to act
for him or her before the Internal Revenue
Service.


com TOGNA United States Estate Tax Return

(Rev. November 1981) Estate of nonresident not a citizen of the United States OMB No. 1545-0531
Pevartrant of the Tressury (Section references are to the Internal Revenue Code.) Brpires 10-9134

Attach supplemental documents and translations. Show amounts in United States dollars.

Decedent's first name and middle initial | Decedent's last name Date of death
Place of death Domicile at time of death Citizenship (Nationality) Social security number (if any)
Date of birth Place of birth Business or occupation
Name of personal representative Name of attorney for estate
In
United | Address Address
States
Name of personal representative Name of attorney for estate
Outside
United | Address ‘Address
States
Tax Computation
1 Taxable estate (from Schedule B, line 8) . : —
2 Total taxable gifts of tangible or intangible property located in the u: s, transferred (directly. or ‘ndirectly)
by the decedent after December 31, 1976, and not included in the gross estate (see section 2511) . 2
3 Total (add lines 1 and 2). 6 6 1 ee 3
4 Tentative tax on the amount on line 3 (see instructions). . . 4
5 Tentative tax on the amount on line 2 (see instructions) . =e
6 Gross estate tax (subtract line 5 from line 4)... 6 ee ee ee |B
7 Unified credit—enter lesser of line 6 amount or maximum allowed (see instructions). . . . . « 7 _|
8 Balance (subtract line 7 fromline6). - 6. ee ee ee 8.
9 Credit for State death taxes (see instructions and attach creditevidence). . . . - . . » ss « + |_9
10 Balance (subtract line 9 from line8). . . - toe 10
11 Credit for Federal gift taxes (see sections 2102 and 2012 and attach computation) i
12 Credit for tax on prior transfers (attach Schedule Q from Form 706). . . . Li2
13 Total (add lines 11 and 12). 2 2 2 ee ee ee LL
14 Balance (subtract line 13 from line 10)... 6 ee ee ee ee [AA
15 Earlier payments (see instructions and attach explanation). . . . . . . (45 |
16 U.S. Treasury bonds redeemed to pay estate tax. . . . . .. . . . LI6
17 Total (add lines 15 and 16). 2 2 0 ee ee PAT
18 Balance due (subtract line 17 from line 14) (see instructions) . 18

Under penalties of perjury, | declare that | have examined this return, including the additional sheets attached, id to the best of my knowledge and belief
and cormplefer | understand that a complete return requires lating all property constituting the part of the decedent's "proms estate as defined by the statue) situated

is true, correct,
e United States.

presentative) ~ (ate)

jature of preparer (other than personal representative) (Address) —— (ate)
For Paperwork Reduction Act Notice, see page 1 of the instructions.


Form 706NA (Rev. 11-81) Page 2

Yes] No) [Yes | No.
bait secant ete ||? Siar
b Were letters testamentary or of administration granted in the U.S. at either the time of transfer or the time
for the estate?. . Loe of death? |
If granted to persons other than those ‘fling the return, Z Y If “Yes,” attach Schedule G from Form 706. @ We,
include names and addresses on page 1. YJ} awn the date of death had the decedent created any
2 Did the decedent, at the time of death, own any— |W a existing trusts that included property located in the
a Real property located in the U.S.? : —_ USS. either when the trust was created or when the
b U.S. corporate stock? . . | |__| decedent died? —
¢ Debt obligations of (1) a U.S. person or ‘(@) the US., if “Yes,” attach Schedule G from Form 706. WAZ,
a State or any political subdivision, or the District of Qa At the date of death did the decedent have a general
Columbia? . . 1 ss + «| _|-_] power of appointment over any property located in
d_ Other property located in the U.S | the u.s.2 :
3. Was the decedent engaged in business in the U.S. at b Or, at any time, exercise or release the power?. .
dateofdeath?. . we ee If “Yes” to either a orb, attach Schedule H, Form 706.

A general power of appointment means any power of
sonally or through an agent, to a safe deposit box appointment exercisable in favor of the decedent, the
on ee decedent's estate, the decedent's creditors, or the credi-
2 +++ ++ +: + |___]___} tors of the decedent's estate, and includes the right of a
5 At date of death did the decedent own any property beneficiary to appropriate or consume the principal of a
located in the U.S. as a joint tenant with right of sur- trust. For complete definition, see section 2041.
vivorship; as a tenant by the entirety; or, with surviv- 10a Have Federal gift tax returns ever been filed? .
ing spouse, as community property? .

4 At date of death did the decedent have access, per-

Li
AC |

6 Did the decedent lose U.S. citizenship within 10 years b Periods covered >.
of death? . . c¢ Internal Revenue offices where filed >

Schedule A Gross Estate inthe United States (see instructions)

Yes | No

Do you elect to value the decedent's gross estate at a date or dates after the decedent's death (as authorized by section 2032)?

To make the election, you must check this box “Yes” and file Form 706NA on time. If you check “Yes” complete columns (c), (d), and (e).
If you check ‘‘No”’ complete column (e) and leave columns (c) and (d) blank.

(a) (b) (c) (a) (e)
Item ‘ti Alternate Alternate value in | Value at date of death
No. Description of property and stock valuation date U.S. dollars in U.S. dollars
1
(If you need more space, attach additional sheets of same size.)
Total

Schedule 3 | Taxable Estate

You must document lines 2 and 4 for the deduction on line 5 to be allowed.

1 Gross estate in the U.S. (Schedule Atotal) ©. 2 6 6 6 ee ee ee ee ee

2 Gross estate outside the U.S. (see instructions)

3 Entire gross estate wherever located (add amounts on lines ‘Land 2.

4 Amount of funeral expenses, administration expenses, decedent's debts, ‘mortgages and Ii liens, and losses
during administration (attach itemized schedule) (see instructions) . .

5 Deduction for expenses, claims, etc. (divide line 1 by line 3 and multiply the result by line 4) (see
instructions) ee

6 Charitable deduction (attach Schedule °, Form 706) . Co

7 Total deductions (add lines 5 and 6). - a
8 Taxable estate (subtract line 7 from line ». ee



a~

Form 706NA (Rev. 11-81)

Detach at perforation and file only pages 1 and 2.

Page 3

a

Form 706NA Instructions
(References are to the Internal Revenue Code)

Paperwork Reduction Act Notice—The Pa-
perwork Reduction Act of 1980 says we
must tell you why we are collecting this in-
formation, how we will use it, and whether
you have to give it to us. We ask for the in-
formation to carry out the Internal Revenue
laws of the United States. We need it to en-
sure that you are complying with these laws
and to allow us to figure and collect the
right amount of tax. You are required to
give us this information.

Form 706. In order to complete this re-
turn, you may need to obtain Form 706,
United States Estate Tax Return, and its
separate instructions. You must obtain a
copy of Form 706 if you intend to claim
a marital deduction, a charitable deduction,
or a credit for tax on prior transfers, or if
the gross estate located in the United States
includes property transferred by the dece-
dent within 3 years before death. You will
need the instructions to Form 706 to explain
how to value stocks and bonds. If the dece-
dent was a U.S. expatriate, you will need the
tax rate tables in the instructions to Form

GENERAL INSTRUCTIONS

A. Purpose.—Form 706NA is used to
compute estate tax liability for nonresident
alien decedents. The tax is imposed on the
transfer of the decedent’s taxable estate,
rather than on the receipt of any part of it:

If you need tax information not in these
instructions, see Publication 448, Federal
Estate and Gift Taxes. For information about
transfer certificates for U.S. assets, write to
the Director of International Operations,
P.O. Box 896, Benjamin Franklin Station,
Washington, D.C. 20044.

B. ions.—The following terms are
used often in these instructions:

1, The U.S. means the 50 States and the
District of Columbia.

2. A nonresident alien decedent means a
decedent who is neither domiciled in nor a
citizen of the U.S. at the time of death. For
purposes of this form, a citizen of a U.S.
possession is not a U.S. citizen.

3. A U.S. expatriate is one who lost U.S.
citizenship within 10 years before the date
of death, and for whom it is reasonable to
assume that a main purpose in doing so was
to avoid U.S. taxes. The personal repre-
sentative has the burden of proving other-
wise. See specific instructions for question
6 and Schedule A of page 2, and lines 4-5
and 7 of page 1.

C. Who Must File—The personal repre-
sentative must file Form 706NA if the date
of death value of the decedent's gross estate
located in the U.S. exceeds the filing limit.
The filing limit is $60,000 reduced by the
sum of (1) the gift tax specific exemption
(section 2521) allowed with respect to gifts
made between September 9, 1976, and De-
cember 31, 1976, inclusive, and (2) the total
taxable gifts made after December 31, 1976,
that are not included in the gross estate.

The personal representative is the execu-
tor, executrix, administrator, or administra-
trix of the deceased person's estate. If no
personal representative is appointed, quali-
fied, and acting in the U.S., 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 prefer-
able that they join in filing one complete
return. Otherwise, each must file as com-

plete a return as possible, including a full
description of the property and each per-
son's name who holds an interest in it.

D. When and Where to File.—File Form
7O6NA within 9 months after the date of
death unless an extension of time to file was
granted. In that case, attach a copy of the
approved Form 4768, Application for Exten-
sion of Time to File U.S. Estate Tax Return
and/or Pay Estate Tax.

Send Form 706NA to the Internal Reve-
nue Service Center, Philadelphia, PA 19255.

E. Penalties.—By law, additional tax may
be charged if the return is filed late or the
tax is paid late (section 6651),

F. Death Tax Treaties.—Death tax trea-
ties are in effect with the following countries.

Australia Japan

Finland Netherlands

France Norway

Greece Republic of South Africa
treland Switzerland

Italy United Kingdom

SPECIFIC INSTRUCTIONS

Attachments.—lf the decedent died tes-
tate, attach a certified copy of the will to
Form 7O6NA. 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 appraisal lists,
needed for explanation. Also attach copies
of all available U.S. gift tax returns the de-
cedent filed. Other documents may be re-
quired as explained in these instructions.

Attach an English translation to all docu-
ments in other languages.

How to complete Form 706NA

First, enter the decedent's name and the
other information called for on the first page
above the Tax Computation. Then complete
questions 1a—10c on the top of the second
page.

The tax is imposed on the decedent's
gross estate in the United States, reduced
by allowable deductions. Compute 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
the Tax Computation schedule.

Page 2

Question 6.—If you answer “Yes,” but
maintain that avoiding U.S. taxes was not
‘one of the main reasons for the decedent's
loss of citizenship, attach documents to sus-
tain your position.

See General Instruction B3.

Schedule A—Before you complete Sched-
ule A, you must determine what assets are
included in the decedent’s entire gross es-
tate wherever located. There is no space on
the form to itemize the entire gross estate.
You need not attach a separate itemized
list of the gross estate outside the U.S. un-
less you claim deductions on Schedule B.
See the instructions for Schedule B.

The entire gross estate wherever located
is figured the same way for a nonresident
alien decedent as for a U.S. citizen or resi-
dent. It consists of all property the decedent
beneficially owned, wherever located, and in-
cludes the following property interests:

(a) Generally, the full value of property
the decedent owned at the time of death
either as a joint tenant with right of survivor-
ship or as a tenant by the entirety.

(b) Property the decedent and a surviving
spouse owned as community property to the
extent of the decedent's interest in the prop-
erty under applicable State, possession, or
foreign law.

(c) A surviving spouse's dower or curtesy
interest and all substitute interests created
by statute.

(d) Proceeds of insurance on the dece-
dent's life, generally including proceeds re-
ceivable by beneficiaries other than the es-
tate.

(e) Several kinds of transfers the dece-
dent made before death.

(f) 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.

(g) Certain annuities to surviving bene-
ficiaries.

For additional information concerning
joint tenancies, annuities, life insurance,
transfers during life and powers of appoint-
ment, see Publication 448.

Enter on Schedule A all of the assets that
meet both the following tests:

(1) they are included in the “entire gross
estate wherever located,” and

(2) they are located in the U.S.

Unless a treaty provides otherwise (see
instruction F, Death Tax Treaties), use the
following rules to determine whether assets
are located in the U.S.

(a) Real estate and tangible personal
Property are located in the U.S. if they are
physically located there. An exception is
made for works of art imported into the
U.S. solely for public exhibition.

(b) No matter where stock certificates are
physically located, stock of corporations or-
ganized in or under U.S. law is property lo-
cated in the U.S., and all other corporate
stock is property located outside the U.S.

(c) Proceeds of insurance policies on the
decedent's life are property located outside
the U.S.

(d) Debts are generally property located
in the U.S. if they are debts of a U.S. citizen
or resident, a domestic partnership or cor-
poration, a domestic estate or trust, the
United States, a State or State’s political
subdivision, or the District of Columbia.

However, a domestic corporation’s debt
obligation is treated as located outside the
U.S. if the interest from it (had it been re-
ceived at the time of death) would have been
treated as income from outside the U.S. be-
cause the corporation derived less than
20% of its gross income from sources in
the U.S. during its 3 tax years before the de-
cedent’s death (section 861(a)(1)(B)), or if
the obligation was treated as the obligation
of a foreign corporation under the interest
equalization tax and meets the other re-
quirements of either section 861(a)(1)(G)
or section 861(a)(1)(H).

(e) The following deposits are treated as
located outside the U.S. if they are not ef-
fectively connected with conducting a trade
or business within the U.!

(1) a deposit with a U.S, bank or a U.S.
banking branch of a foreign corporation.

(2) a deposit or withdrawable account
with a savings and loan association char-
tered and supervised under Federal or State
law.

(Continued on page 4)