Form 706NA (Rev. 2-84)

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. However, if an asset is
included in the decedent's total gross estate
under one of the transfer provisions (sections
2035, 2036, 2037 and 2038) itis treated as
located in the US. ifit fulfills these rules either at
the time of the transfer or at the time of death.
For example, if an item of tangible personal
property was physically located in the U.S. on the
date of a section 2038 transfer, but had been
moved outside the U.S. at the time of the
decedent's death, the item would be considered
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
corporation's name, the number of shares,
whether common or preferred (if preferred, what
issue), the par value (when needed for
identification), CUSIP number if available, 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, interest
rate, each date when interest is payable, CUSIP
number if available, and series number (if more
than one issue). Give the exchange where the
bond is listed; if it is unlisted, give the
corporation's main business office.

Ifyou are required to file Schedule(s) E, G or
H from Form 706, you need not enter the assets
reported on those schedules on Schedule A of
this Form 706NA. Instead attach the schedule(s)
to Form 706NA, enter Total from Schedule ,
Form 706,” and enter the total value(s) from the
attached schedule(s) in either column (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,
property 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 property distributed, sold,
exchanged, or otherwise disposed of within 6
months after the decedent's death is valued as of
the date of the disposition. Any property not
disposed of during that period is valued as of the
date 6 months after the decedent's death.

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 return; or if none
was filed, a certified copy of the estate inventory
and the schedule of debts and charges that were
filed with the foreign probate court or as part of
the estate’s administration proceedings. 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 deductions fully
and identity 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; administration
expenses; claims against the estate; unpaid
mortgages and other liens; and uncompensated
losses that were incurred during 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 contracted 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 property taxes
accrued after death.

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

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.—Charitable deduction: Unless a
treaty allows otherwise, you may take a
charitable deduction only if the transfer was toa
domestic entity 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 decedent
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.

Marital deduction: treaty only.—Unless a
treaty allows otherwise, you may not take a
marital deduction. If you claim a marital
deduction under a treaty, include the deduction
‘on line 6. Attach Schedule M, Form 706, anda
statement showing your computation of the
marital deduction.

See section 2518 for the rules governing
disclaimers of interest in property.

Page 1
Lines 4-5.—Use the following rates unless
the decedent was a U.S. expatriate. In that case,

use the rates given in Table A of the Instructions
for Form 706.

Mtngzcine 3) enter Ofamount
$ 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 fora U.S. expatriate it is $13,000. For a
citizen of a U.S. possession (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 located 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 1981 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, use Table C in the Form 706
instructions to figure the supposed credit that
would be allowable on the entire line 1 amount
(reduced 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
Schedule 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 official of
the taxing State. The certificate should show: the
total tax charged, any discount allowed, any
penalties and interest imposed, the tax actually
paid, and each payment date. 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.

Ifyou later recover any of the State tax for
which you claim this credit, notify the Internal
Revenue Service Center, Philadelphia, PA 19255
within 30 days of receiving any refund of State

axes.

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 redeemed 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 Revenue Service for the
face value in U.S. dollars.

Signature.—Form 706NA must be signed.
Each executor must verify and sign it. If another
person prepares Form 706NA for the executor,
the preparer must also sign. The executor may
use Form 2848, Power of Attorney and
Declaration of Representative, or Form 2848-D,
Tax Information Authorization and Declaration of
Representative, to authorize another person to
act for him or her before the Internal Revenue
Service.


rom ZO6NA United States Estate Tax Return

(Rev. February 1984) Estate of nonresident not a citizen of the United States OMB No. 1545-0571

Department of the Treasury

Department of the Treast (Section references are to the Internal Revenue Code.)

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 executor Name of attorney for estate

In
United | Address ‘Address
States

Name of executor Name of attorney for estate
Outside
United | Address Address
States
Tax Computation

1 Taxable estate (from Schedule B, line 8) 1
2 Total taxable gifts of tangible or intangible property located i in the Us Ss, ‘transferred Girectly 0 or indirectly)

by the decedent after December 31, 1976, and not included in the gross estate (see section 2511) . . 2
3 Total(addlinesland2) 2. 2 ee eee ee LS
4 Tentative tax on the amount online 3(see instructions) . 2... 1 1 ee ee 4
5 Tentative tax on the amount on line 2 (see instructions) 5
6 Gross estate tax (subtract line 5 from line 4) 6
7 Unified credit—enter lesser of line 6 amount or maximum allowed (see instructions) wee ee LT
8 Balance (subtract line 7 from line.6) 8
9 Credit for State death taxes (see instructions and attach credit evidence) 9
10 Balance (subtract line 9 fromline8) . we ee. Plo
11 Credit for Federal gift taxes (see sections 2102 and 2012 and attach computation) jut
12 Credit for tax on prior transfers (attach Schedule Q from Form 706) l 12
13° Total(addlineslland12) . 2 2. ee eee ee ee. LS
14 Balance (subtract line 13 from line 10) cee Gd
15 Earlier payments (see instructions and attach explanation) . 45
16 U.S. Treasury bonds redeemedtopayestatetax . . . .... 1... 16
17 Total(addlines15and16) . 2. ee ee ee LEZ
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, 7 ‘any, and to the Tr my Tnowledge and belief, it is true, correct, and
complete. | understand that a complete return requires listing all property constituting the part of the decedent's gross estate (as defined by the statute) situated in the United States.

(Signature of preparer (other than executor) (Address) (Date)

For Paperwork Reduction Act Notice, see the first page of the instructions. Form 7O6NA (Rev. 2-84)


Form 706NA (Rev. 2-84) Page 2

Yes | No Yes | No
la Didthedecedentdietestate? . . . 6a Had the decedent ever been a citizen of the
b Were letters testamentary or of administration United States? . .
granted fortheestate? . . . . b_ If “Yes,” did the decedent lose U. s. ctiznshio
If granted to persons other than those filing the within 10 years of death? aes
return, include names and addresses on page 1. 7 Did the decedent make any transfer cof property
2 Did the decedent, at the time of death, own any: that was located in the Us. Saueanee of
a Real property locatedintheU.S.? . . . . . sections 2035, 2036, 2037, or 2038 (see the in-
b U.S.corporatestock? . . . structions for Form 706, Schedule G?...
c Debt obligations of (1) a U.S. person or or (2) the If Yes,” attach Schedule G from Form 706.
U.S., a State or any political subdivision, or the 8 At the date of death, had the decedent created
District of Columbia? Foe ee any existing trusts that included property located
d_Other property located inthe U.S.?_. in the U.S. either when the trust was created or
3 Was the decedent engaged in business in the when the decedent died? .
U.S.atdateofdeath? . . |. If “Yes,"' attach Schedule G from Form 706.
4 At date of death, did the decedent have access, 9a_ At the date of death, did the decedent have a
personally or through an agent, to a safe deposit general power of appointment over any property
boxlocatedintheU.S.?_. . . locatedintheU.S.? . .
5 At date of death, did the decedent own any b Or, at any time, exercise or release the power?
property located in the U.S. as a joint tenant with If “Yes,” to eithera or b, attach Schedule H, Form 706.
right of survivorship; as a tenant by the entirety; 10a _ Have Federal gift tax returns ever been filed? .
or, with surviving spouse, as community
Property? . . . b Periodscovered Wo eeeeeeeeeeeeee eee
If “Yes,” attach Schedule E from Form 706. ¢_Internal Revenue offices where filed >
Gross Estate in the 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). You may leave columns (c) and (d) blank or you may use them to expand your column (b) description.

(a) (b) () (@) (e)
Item Description of property and securities Alternate Alternate value in Value at date of death
No. For securities, give CUSIP number, if available. valuation date US. dollars in U.S. dollars

1

(if you need more space, attach additional sheets of same size.)
Total eee ere
Success Taxable Estate
You must document lines 2 and 4 for the deduction on line 5 to be allowed.

1 Gross estate inthe U.S.(ScheduleAtotal) 2 2 6 6. we ee a
2. Gross estate outside the U.S. (see instructions) . . Se ee ee ee LZ
3 Entire gross estate wherever located (add amounts on lines 1 and 2) ee ee 3
4 Amount of funeral expenses, administration expenses, decedent's debts, mortgages and liens, and losses
during administration (attach itemized schedule) (see instructions) . . . . . . 4
5 Deduction for expenses, claims, etc. (divide line 1 by line 3 and multiply the result by line 4) G5e
instructions). 5
6 Charitable deduction (attach ‘Schedule 0, Form 706) and marital deduction ‘attach Schedule M, “Form
706 and computation). . . ee 6
7 Total deductions (add lines 5 and 6) ee 7
8 Taxable estate (subtract line 7 from line b po 8



Form 706NA (Rev. 2-84)

4A _ Detach at perforation and file only pages 1 and 2.

A Page 3

Form 706NA Instructions

(Section references are to the Internal Revenue
Code unless otherwise noted.)

Paperwork Reduction Act Notice— We ask
for this information to carry out the Internal
Revenue laws of the United States, We need it to
ensure that you are complying with these laws
and to allow us to figure and collect the right
amount of tax. You are required to give us this,
information.

Form 706.—In order to complete this return,
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 you answer ‘‘Yes,” to questions 5, 7, 8 or 9.
You will need the instructions to Form 706 to
explain how to value stocks and bonds. If the
decedent was a U.S. expatriate, you will need the
tax rate tables in the instructions to Form 706.
Make sure that you obtain the revision of Form
706 that is applicable for the date of the
decedent's death.

General Instructions

A. Purpose of Form .—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 Foreign
Operations District, P.O. Box 19007,
Washington, D.C. 20036.

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

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

2. Anonresident 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
US. citizen

3. AUS. 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 executor has the burden of proving
otherwise. 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 executor 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
December 31, 1976, inclusive, and (2) the total
taxable gifts made after December 31, 1976,
that are not included in the gross estate.

The executor is the personal representative,
executor, executrix, administrator, or
administratrix of the deceased person's estate. If
no executor is appointed, qualified, and acting in
the 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 preferable that they join in filing one
complete return. Otherwise, each must file as
complete a return as possible, including a full
description of the property and each person's
name who holds an interest in it.

D. When and Where to File.—File Form
706NA 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 Extension of Time to File
U.S. Estate Tax Return and/or Pay Estate Tax.

Send Form 706NA to the Internal Revenue
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 treaties
are in effect with the following countries.

Australia Italy

Austria Japan

Canada Netherlands

Finland Norway

France Republic of South Africa
Greece ‘Switzerland

Ireland United Kingdom

Specific Instructions

Attachments.—If the decedent died testate,
attach a certified copy of the will to Form 706NA.
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 decedent filed. Other
documents may be required as explained in these
instructions.

Attach an English translation to all documents
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 6a.—If you answer ‘‘Yes,"” please
attach a statement listing: the citizenship of the
decedent's parents; whether the decedent
became a U.S. citizen through a naturalization
proceeding in the U.S.; and when the decedent
lost U.S. citizenship.

Question 6b.—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 sustain your
position. See General Instruction B3.

Question 9.—A general power of
appointment means any power of appointment
exercisable in favor of the decedent, the
decedent's estate, the decedent's creditors, or
the creditors of the decedent’s estate, and
includes the right of a beneficiary to appropriate
or consume the principal of a trust. Fora
complete definition, see section 2041.

Schedule A

Before you complete Schedule A, you must
determine what assets are included in the
decedent's entire gross estate 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. unless 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 resident. It
consists of all property the decedent beneficially
owned, wherever located, and includes 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 survivorship 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 property
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 decedent's
life, generally including proceeds receivable by
beneficiaries other than the estate.

(e) Several kinds of transfers the decedent
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
beneficiaries.

For additional information concerning joint
tenancies, annuities, life insurance, transfers
during life and powers of appointment, 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
‘organized in or under U.S. law is property located
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

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

However, a domestic corporation's debt
obligation is treated as located outside the U.S. if
the interest from it (had it been received at the
time of death) would have been treated as
income from outside the U.S. because the
corporation derived less than 20% of its gross
income from sources in the U.S. during its 3 tax
years before the decedent'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
requirements 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 effectively
connected with conducting a trade or business
within the U.S.:

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

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

(Continued on page 4)