1545-0260 supporting statement

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Supporting Statement
Form 706-CE
OMB Control Number 1545-0260


1. CIRCUMSTANCES NECESSITATING COLLECTION OF INFORMATION

Code section 2014 allows a credit against Federal estate taxes for foreign death taxes actually paid, subject to certain limitations. This credit is computed on Form 706, United States Estates (and Generation‑Skipping Transfer) Tax Return.

2. USE OF DATA

Code section 2014(d) requires the taxpayer to submit to the IRS proof of having actually paid the foreign death taxes.  Form 706-CE is used for this purpose.

3. USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN

 We have no plans at this time to offer electronic filing because of the low volume compared to the cost of electronic enabling.
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4. EFFORTS TO IDENTIFY DUPLICATION

We have attempted to eliminate duplication within the agency wherever possible.

5. METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES

There are no methods to minimize burden on small businesses or other small entities.

6. CONSEQUENCES OF LESS FREQUENT COLLECTION ON FEDERAL PROGRAMS OR POLICY ACTIVITIES

IRS uses the data from the form to allow a credit against Federal estate taxes for death taxes paid. If this information is not collected, or collected less frequently, the agency would not accurately be aware of the foreign taxes actually paid (subject to certain limitations) under code section 2014.

7. SPECIAL CIRCUMSTANCES REQUIRING DATA COLLECTION TO BE INCONSISTENT WITH GUIDELINES IN 5 CFR 1320.5(d)(2)

There are no special circumstances requiring data collection to be inconsistent with guidelines in CFR 1320.5(d)(2).

8. CONSULTATION WITH INDIVIDUALS OUTSIDE OF THE AGENCY ON  AVAILABILITY OF DATA, FREQUENCY OF COLLECTION, CLARITY OF  INSTRUCTIONS AND FORMS, AND DATA ELEMENTS

Periodic meetings are held between IRS personnel and representatives of the American Bar Association, the National Society of Public Accountants, the American Institute of Certified Public Accountants, and other professional groups to discuss tax law and tax forms. During these meetings, there is an opportunity for those attending to make comments regarding Form 706-CE.

In response to the Federal Register Notice (80 F.R. 66620), dated  October  29, 2015, we received no comments during the comment period regarding Form 706-CE.

9. EXPLANATION OF DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS

No payment or gift has been provided to any respondents .

10. ASSURANCE OF CONFIDENTIALITY OF RESPONSES

Generally, tax returns and tax return information are confidential as required by 26 USC 6103.

11. JUSTIFICATION OF SENSITIVE QUESTIONS

A privacy impact assessment (PIA) has been conducted for information collected under this request as part of the “Individual Master File (IMF)” system and a Privacy Act System of Records notice (SORN) has been issued for this system under IRS 24.030--Customer Account Data Engine Individual Master File, formerly Individual Master File, and IRS 34.037--IRS Audit Trail and Security Records System.  The Department of Treasury PIAs can be found at http://www.treasury.gov/privacy/PIAs/Pages/default.aspx.

12. ESTIMATED BURDEN OF INFORMATION COLLECTION

Number of		Time per		Total	
Responses		Response		Hours

Form 706-CE		2,250			1.72 hrs.		3,870

13. ESTIMATED TOTAL ANNUAL COST BURDEN TO RESPONDENTS

There is no estimated annual cost burden to the respondents.

14. ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT

After consultation with various functions within the Service, we have determined that the cost of developing, printing, processing, distribution, and overhead for this form is $225.

15. REASONS FOR CHANGE IN BURDEN

There are no changes being made to the form at this time. 

This form is being submitted for renewal purposes.

16. PLANS FOR TABULATION, STATISTICAL ANALYSIS AND PUBLICATION

There are no plans for tabulation, statistical analysis and publication.

17. REASONS WHY DISPLAYING THE OMB EXPIRATION DATE IS INAPPROPRIATE

See below.

18. EXCEPTION TO THE CERTIFICATION STATEMENT

There are no exceptions to the certification statement.


Note: The following paragraph applies to all of the collections of information in this submission:

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid OMB control number.  Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.



OMB EXPIRATION DATE

We believe the public interest will be better served by not printing an expiration date on the form(s) in this package.

Printing the expiration date on the form will result in increased costs because of the need to replace inventories that become obsolete by passage of the expiration date each time OMB approval is renewed.  Without printing the expiration date, supplies of the form could continue to be used.

The time period during which the current edition of the form(s) in this package will continue to be usable cannot be predicted.  It could easily span several cycles of review and OMB clearance renewal.  In addition, usage fluctuates unpredictably.  This makes it necessary to maintain a substantial inventory of forms in the supply line at all times.  This includes supplied owned by both the Government and the public.  Reprinting of the form cannot be reliably scheduled to coincide with an OMB approval expiration date.  This form may be privately printed by users at their own expense.  Some businesses print complex and expensive marginally punched continuous versions, their expense, for use in their computers.  The form may be printed by commercial printers and stocked for sale.  In such cases, printing the expiration date on the form could result in extra costs to the users.

Not printing the expiration date on the form(s) will also avoid confusion among taxpayers who may have identical forms with different expiration dates in their possession.

For the above reasons we request authorization to omit printing the expiration date on the form(s) in this package.