Form 706-GS(T) - Generation-Skipping Transfer Tax Return For Terminations

Instructions for Form
706-GS(T)

Department of the Treasury
Internal Revenue Service

(Rev. November 2014)

Generation-Skipping Transfer Tax Return for Terminations
Section references are to the Internal Revenue
Code unless otherwise noted.

Future Developments
For the latest information about
developments related to Form
706-GS(T) and its instructions, such as
legislation enacted after they were
published, go to www.irs.gov/
form706gst.

What's New

On June 26, 2013, the United States
Supreme Court held that Section 3 of
the Defense of Marriage Act, which said
that the terms “marriage” and “spouse”
only apply to heterosexual couples, was
unconstitutional. (United States v.
Windsor, 570 U.S. 12 (2013)). The
ruling impacts a number of federal laws,
including those governing the reporting
and collection of federal taxes. For
federal tax purposes, the IRS
recognizes same-sex marriages that are
valid in the state where they were
entered into, regardless of the married
couple’s residence. See Rev. Rul.
2013-17, 2013–38 I.R.B. 201, available
at www.irs.gov/pub/irs-irbs/irb13-38.pdf.
If you believe the new law may affect
your estate or gift tax liability or filing
requirement, please continue to monitor
IRS.gov for additional guidance on the
application of Windsor.

General Instructions
Purpose of Form

Form 706-GS(T) is used by a trustee to
figure and report the tax due from
certain trust terminations that are
subject to the generation-skipping
transfer (GST) tax.

Who Must File

In general, the trustee of any trust that
has a taxable termination (defined
below ) must file Form 706-GS(T) for the
tax year in which the termination
occurred.

When To File

Generally, the trustee must file Form
706-GS(T) by April 15th of the year
following the calendar year in which the

Oct 29, 2014

termination occurs. If the due date falls
on a Saturday, Sunday, or legal holiday,
file on the next business day.
If you are not able to file the return by
the due date, you may request an
extension of time to file by filing Form
7004, Application for Automatic
Extension of Time To File Certain
Business Income Tax, Information, and
Other Returns. The extension is
automatic, so you do not have to sign
the form or provide a reason for your
request. You must file Form 7004 on or
before the regular due date of Form
706-GS(T). See Form 7004 for more
information.

Where To File

File Form 706-GS(T) at the following
address:
Department of the Treasury
Internal Revenue Service
Cincinnati, OH 45999

Trusts
Nonexplicit trusts. An arrangement
that has substantially the same effect as
a trust will be treated as a trust even
though it is not an explicit trust.
Examples of such arrangements are
insurance and annuity contracts,
arrangements involving life estates and
remainders, and estates for years.
In general, a transfer of property in
which the identity of the transferee is
conditioned on the occurrence of an
event is a transfer in trust. This rule
does not apply to a testamentary trust,
however, if the event is to occur within 6
months of the transferor's date of death.
Nonexplicit trusts do not include
decedents' estates.
In the case of a nonexplicit trust, the
person in actual or constructive
possession of the property involved is
considered the trustee and is liable for
filing Form 706-GS(T).
If you are filing this return for a
nonexplicit trust, see the instructions for
line 1b.
Separate trusts. You must treat as
separate trusts:

Cat. No. 10829R

Portions of a trust that are attributable
to transfers from different transferors
and
Substantially separate and
independent shares of different
beneficiaries in a trust.
If you are the trustee for separate
trusts as described above, you must file
a single Form 706-GS(T) but separate
Schedules A for each separate trust, as
that term is used here.

Terminations Subject to
GST Tax

A termination may occur by reason of
death, lapse of time, release of a power,
or any other means.
In general, all taxable terminations
are subject to the GST tax. A taxable
termination is the conclusion of an
interest in property held in trust unless:
Immediately after the termination, a
non-skip person has an interest in the
property or
At no time after the termination may a
distribution be made from the trust to a
skip person.

Exceptions
Irrevocable trusts. Except as
described under Additions to
irrevocable trusts below, the GST tax
does not apply to any termination of an
interest in a trust that was irrevocable on
September 25, 1985. Any trust in
existence on September 25, 1985, will
be considered irrevocable unless:
1. On September 25, 1985, the
settlor held a power with respect to such
trust that would have caused the value
of the trust to be included in the settlor's
gross estate for federal estate tax
purposes by reason of section 2038
(regarding revocable transfers) if the
settlor had died on September 25, 1985;
or
2. Regarding a policy of life
insurance that is treated as a trust under
section 2652(b), the insured possessed
an incident of ownership on September
25, 1985, that would have caused the
insurance proceeds to be included in
the insured's gross estate for federal
estate tax purposes if the insured had
died on September 25, 1985.

For more information, see
Regulations section 26.2601-1(b)(i) and
(ii).
Trusts containing qualified terminable interest property. Irrevocable
trusts in existence on September 25,
1985, that hold qualified terminable
interest property (QTIP) (as defined in
section 2056(b)(7)) as a result of an
election under section 2056(b)(7) or
2523(f), are treated for purposes of the
GST tax as if the QTIP election had not
been made. Thus, transfers from such a
trust will not be subject to the GST tax.
Additions to irrevocable trusts. If an
addition has been made after
September 25, 1985, to an irrevocable
trust, the termination of any interest in
the trust may be subject in part to the
GST tax. Additions include constructive
additions described in Regulations
section 26.2601-1(b)(1)(v).
Medical and educational exclusion.
If all of the property to which the
termination applied has been distributed
and used for medical or educational
expenses of the transferee such that if
the transfer had been made inter vivos
by an individual, it would not have been
subject to gift tax by reason of the
medical and educational exclusion, then
the termination is not a
generation-skipping transfer, and you
do not have to file this form to report the
termination.

Transition Rule for Revocable
Trusts

The GST tax will not apply to any
termination of an interest in a revocable
trust, provided:
The trust was executed before
October 22, 1986;
The trust as it existed on October 21,
1986, was not amended after October
21, 1986, in any way that created or
increased the amount of a
generation-skipping transfer;
Except as provided in Exceptions to
Additions Rule later, no additions were
made to the trust; and
The settlor died before January 1,
1987.
A revocable trust is any trust that on
October 22, 1986, was not an
irrevocable trust, as defined previously,
and would not have been an irrevocable
trust had it been created before
September 25, 1985.
The instructions under Trusts
containing qualified terminable interest
property, previously, apply also to
revocable trusts covered by these
transition rules.

Amendments to revocable trusts. An
amendment to a revocable trust in
existence on October 21, 1986, will not
be considered to result in the creation
of, or an increase in the amount of, a
generation-skipping transfer where:
The amendment is administrative or
clarifying in nature, and it only
incidentally increases the amount
transferred to a skip person (defined
below), or
It is designed to perfect a marital or
charitable deduction for an existing
transfer, and it only incidentally
increases the amount transferred to a
skip person (defined later).
See Regulations section 26.2601-1(b)
(2)(vii) for examples demonstrating
these rules.
Additions to revocable trusts. If an
addition (including a constructive
addition) to a revocable trust is made
after October 21, 1986, and before the
death of the settlor, all subsequent
terminations of interests in the trust will
be subject to the GST tax if the other
requirements of taxability are met. For
settlors dying before January 1, 1987,
any addition made to a revocable trust
after the death of the settlor will be
treated as made to an irrevocable trust.

Transition Rule in Case of
Mental Disability

If the settlor was under a mental
disability on October 22, 1986, the GST
tax may not apply. See Regulations
section 26.2601-1(b)(3) for a definition
of the term “mental disability” and
additional details.

Exceptions to Additions Rule

Do not treat as an addition to a trust any
addition that is made pursuant to an
instrument or arrangement that is
covered by the transition rules
discussed above under Transition Rule
for Revocable Trusts and Transition
Rule in Case of Mental Disability. This
also applies to inter vivos transfers if the
same property would have been added
to the trust by such an instrument. For
examples illustrating this rule, see
Regulations section 26.2601-1(b)(5)(ii).

Definitions
Skip Persons

For termination purposes, skip person
means a trust beneficiary who is either:
1. A natural person assigned to a
generation that is two or more
generations below the settlor's
generation, or

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2. A trust that meets either of the
following conditions:
a. All interests in the trust are held
by skip persons, or
b. No person holds an interest in the
trust, and at no time after the transfer to
the trust may a distribution be made to a
non-skip person.

Interest

A person holds an interest in the trust if,
at the time the determination is made,
the person:
1. Has a current right to receive
income or corpus from the trust,
2. Is a permissible current recipient
of income or corpus from the trust (other
than charitable entities), or
3. Is a charitable or other entity
described in section 2055(a) and the
trust is a charitable remainder annuity
trust, a charitable remainder unitrust, or
a pooled income fund.
Any interest that is created primarily
to postpone or avoid the GST tax is
disregarded.

Non-Skip Person

A non-skip person is any person who is
not a skip person.

Generation Assignment

A generation is determined along family
lines as follows:
1. Where the beneficiary is a lineal
descendant of a grandparent of the
transferor (for example, the donor's
cousin, niece, nephew, etc.), the
number of generations between the
transferor and the descendant is
determined by subtracting the number
of generations between the grandparent
and the transferor from the number of
generations between the grandparent
and the descendant.
2. Where the beneficiary is the lineal
descendant of a grandparent of a
spouse (or former spouse) of the
transferor, the number of generations
between the transferor and the
descendant is determined by
subtracting the number of generations
between the grandparent and the
spouse (or former spouse) from the
number of generations between the
grandparent and the descendant.
3. For this purpose, a relationship
by adoption is considered a blood
relationship. A relationship by half-blood
is considered a relationship by whole
blood.
4. The spouse or former spouse of a
transferor or lineal descendant is
considered to belong to the same

generation as the transferor or lineal
descendant, as the case may be.
A person who is not assigned to a
generation according to the rules above
is assigned to a generation based on his
or her birth date as follows:
1. A person who was born not more
than 121 2 years after the transferor is in
the transferor's generation.
2. A person born more than 121 2
years, but not more than 371 2 years,
after the transferor is in the first
generation younger than the transferor.
3. Similar rules apply for a new
generation every 25 years.
If more than one of the rules for
assigning generations applies to a
beneficiary, the beneficiary is generally
assigned to the youngest of the
generations that apply.
If an entity such as a partnership,
corporation, trust, or estate has an
interest in property, each individual who
has a beneficial interest in the entity (for
example, partners, shareholders, and
beneficiaries) is treated as having an
interest in the property. The individual is
then assigned to a generation using the
rules described above.
Government entities and certain
charitable organizations are assigned to
the transferor's generation.
Terminations in their favor will never be
generation-skipping transfers.

Generation Assignment Where
Intervening Parent is Deceased

If you made a gift or bequest to your
grandchild and at the time you made the
gift or bequest, the grandchild's parent
(who is your or your spouse's or your
former spouse's child) is deceased,
then for purposes of generation
assignment, your grandchild will be
considered to be your child rather than
your grandchild. Your grandchild's
children will be treated as your
grandchildren rather than your
great-grandchildren.
This rule governs generation
assignment of lineal descendants below
the level of grandchild. For example, if
your grandchild is deceased, your
great-grandchildren who are lineal
descendants of the deceased
grandchild are considered your
grandchildren for purposes of the GST
tax.
This rule also applies to other lineal
descendants. For example, if property is
transferred to an individual who is a
descendant of a parent of the transferor,
and that individual's parent (who is a

lineal descendant of the parent of the
transferor) is deceased at the time the
transfer is subject to gift or estate tax,
then for purposes of generation
assignment, the individual is treated as
if he or she is a member of the
generation that is one generation below
the lower of:
The transferor's generation or
The generation assignment of the
youngest living ancestor of the
individual, who is also a descendant of
the parent of the transferor.
The same rules apply to the
generation assignment of any
descendant of the individual.
This rule does not apply to a transfer
to an individual who is not a lineal
descendant of the transferor if the
transferor has any living lineal
descendants.
If any transfer of property to a trust
would have been a direct skip except for
this generation assignment rule, then
the rule also applies to transfers from
the trust attributable to such property.
Ninety-day rule. For purposes of
determining if an individual's parent is
deceased at the time of a testamentary
transfer, an individual's parent who dies
no later than 90 days after a transfer
occurring by reason of the death of the
transferor is treated as having
predeceased the transferor. The 90-day
rule applies to transfers occurring on or
after July 18, 2005. See Regulations
section 26.2651-1(a)(2)(iii).

Multiple Skips

after you file Form 706-GS(T), send an
explanation and we will determine if you
meet reasonable cause criteria. Do not
attach an explanation when you file
Form 706-GS(T). Explanations attached
to the return at the time of filing will not
be considered.
Section 6662 provides penalties for
underpayments of GST taxes which are
over $5,000 and are due to valuation
understatements. A substantial
valuation understatement occurs when
the reported value of property on Form
706-GS(T) is 65% or less of the actual
value of the property. A gross valuation
understatement occurs when the
reported value of the property listed on
Form 706-GS(T) is 40% or less of the
actual value of the property.
Interest will be charged on taxes not
paid by their due date, even if an
extension of time to file is granted.
Interest is also charged on any additions
to tax imposed by section 6651 from the
due date of the return (including any
extensions) until the addition to tax is
paid.
Return preparer. The Small Business
and Work Opportunity Act of 2007
extended return preparer penalties to all
return preparers. Under 6694 and its
regulations, tax return preparers who
prepare any return or claim for refund
which reflects an understatement of tax
liability due to willful or reckless conduct
can be penalized $5,000 or 50% of the
income earned (or income to be
earned), whichever is greater, for the
preparation of each return.

If after a generation-skipping transfer,
the property transferred is held in trust,
then for the purpose of determining the
taxability of subsequent transfers from
the trust involving that property, the
transferor of the property is assigned to
the first generation above the highest
generation of any person who has an
interest in the trust immediately after the
initial transfer.

Signature

Penalties and Interest

Generally, anyone who is paid to
prepare the return must sign the return
in the space provided and fill in the Paid
Preparer Use Only area. See section
7701(a)(36)(B) for exceptions.

Section 6651 provides for penalties for
both late filing and for late payment
unless there is reasonable cause for the
delay. The law also provides penalties
for willful attempts to evade payment of
tax.
The late filing penalty will not be
imposed if the taxpayer can show that
the failure to file a timely return is due to
reasonable cause.
Reasonable Cause Determinations.
If you receive a notice about penalties
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Form 706-GS(T) must be signed by the
trustee or by an authorized
representative.
If you fill in your own return, leave the
Paid Preparer Use Only space blank. If
someone prepares your return and does
not charge you, that person should not
sign the return.

In addition to signing and completing
the required information, the paid
preparer must give a copy of the
completed return to the taxpayer.
Note. A paid preparer may sign original
or amended returns by rubber stamp,
mechanical device, or computer
software program.

Specific Instructions
Complete Form 706-GS(T) in the
following order: Parts I and II,
Schedule A (through line 4),
Schedule B, Schedule A (lines 5
through 10), Part III.

Part I—General
Information
Line 1b. Trust's Employer
Identification Number

All trusts filing Form 706-GS(T) must
have an employer identification number
(EIN). A nonexplicit trust, defined
above, must have an EIN that is
separate from any other entity's EIN and
that will be used only by the entity in its
capacity as the nonexplicit trust.
A trust or nonexplicit trust that does
not have an EIN should apply for one on
Form SS-4, Application for Employer
Identification Number. You can get
Form SS-4, and other IRS tax forms and
publications, by visiting IRS.gov.
Send Form SS-4 to the address
listed under Where To File. If you do not
receive the EIN by the due date for the
706-GS(T), write “Applied for” on
line 1b.
You can also apply for an EIN at
www.irs.gov/businesses.

Part II—Trust Information
Line 4

Whenever property is transferred into a
pre-existing trust, the inclusion ratio
must be refigured. See Multiple
transfers, later, for the rule on how to
refigure the inclusion ratio.

Line 7

If a qualified terminable interest property
deduction was taken by the settlor as
donor spouse or by the executor of a
deceased settlor's estate for the transfer
of any property into this trust, the donor
spouse or the executor, as the case
may be, may have made an election at
that time to treat such transfer for the
purpose of the GST tax as if it was not
qualified terminable interest property. In
this case, you must refer to the gift tax
return (Form 709, United States Gift
(and Generation-Skipping Transfer) Tax
Return) of the donor spouse or the
deceased settlor's estate tax return
(Form 706, United States Estate (and
Generation-Skipping Transfer) Tax
Return) for the information needed to
figure the inclusion ratio.

Schedule A (Lines 1–4)
Note. If you need more than one
Schedule A, make copies before
completing it. Also, make a copy of
Schedule B for each Schedule A you
will file. If you need additional space to
provide all the required information for
any given schedule, attach a separate
sheet of the same size to that schedule.
Combine on a single Schedule A all
terminations from a single trust that
have the same inclusion ratio (as
discussed later). However, you must
complete a separate Schedule A for
each terminating interest that has a
different inclusion ratio. Number each
Schedule A consecutively in the space
provided at the top.

Line 2

For the purposes of line 2, termination
means the conclusion (for example, by
death, lapse of time, or release of
power, etc.) of an interest in property
held in trust unless:
Immediately after the termination, a
non-skip person has an interest in such
property or
At no time after the termination is it
possible for a distribution (including
distributions on termination) to be made
from the trust to a skip person.
Also, if you are reporting separate
trusts, defined above, on this Form
706-GS(T), explain why you are treating
parts of the trust as separate trusts.

Line 3

You may elect alternate valuation under
section 2032 for all terminations in the
same trust that occurred at the same
time as and as a result of the death of
an individual. If you elect alternate
valuation, you must use it to value all
property included in those terminations.
You may not elect alternate valuation
unless the election will decrease both
the total value of the property interests
that were subject to the termination and
the total net GST tax due after the
allowable credit.

Check the box on line 3 of all the
applicable Schedules A if you elect
alternate valuation. Once made, the
election cannot be revoked. You may
make the election on a late filed Form
706-GS(T), provided it is not filed later
than 1 year after the due date (including
extensions).
If you elect alternate valuation, value
the property interest that has been
terminated as follows:
1. Any property distributed or
otherwise disposed of or separated from
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the trust within 6 months after the
termination is valued on the date of
distribution or other disposition. Value
the property on the date it ceases to
form a part of the trust; that is, on the
date the title passes as a result of its
distribution or other disposition.
2. Any property not distributed or
otherwise disposed of within 6 months
following the termination is valued on
the date 6 months after the termination.
3. Any property or interest that is
affected by mere lapse of time is valued
as of the time of termination. However,
you may change this date of termination
value to the value as of the date of
distribution or other disposition to
account for any change that is not due
to mere lapse of time.
If the alternate valuation date falls
after the initial due date of the return,
you must request an extension to file on
Form 7004. The extension is automatic,
so you do not have to sign the form or
provide a reason for your request. See
Form 7004 for more information.

Line 4
Terminations of interests in trusts to
which additions have been made.
As described earlier, when an addition
is made to an irrevocable trust after
September 25, 1985, only the portion of
the trust resulting from the addition is
subject to the GST tax. For terminations,
this portion is the product of the
allocation fraction and the value of the
property subject to the termination
(including accumulated income and
appreciation on that property).
The allocation fraction is a fraction,
the numerator of which is the value of
the addition as of the date it was made
(regardless of whether it was subject to
gift or estate tax). The denominator of
the fraction is the fair market value of
the entire trust immediately after the
addition, less any amount of expenses,
indebtedness, or taxes that would be
allowable as a deduction under section
2053.
When there is more than one
addition, the allocation fraction must be
revised after each addition. The
numerator of the revised fraction is the
sum of:
The value of the portion of the trust
subject to the GST tax immediately
before the last addition, and
The amount of the latest addition.
The denominator of the revised
fraction is the total value of the entire
trust immediately after the latest
addition.

If the addition results from a
generation-skipping transfer, reduce
both the numerator and denominator by
the amount of any GST tax imposed on
the transfer and recovered from the
trust.
Round off the allocation fraction to
five decimal places (for example,
“.00123”).
Column a. Item no. Identify by
separate item number all property in
which an interest has terminated during
the tax year. You may combine under
the same item number all property that
has the same termination date,
valuation date, and unit value, such as
stocks or bonds. Otherwise, assign a
separate item number to each article of
property.
Column b. Description of property.
Describe each article of property
assigned an item number as follows:
Real estate. Describe the real
estate in enough detail so that the IRS
can easily locate it for inspection and
valuation. For each parcel of real estate,
report the area and, if the parcel is
improved, describe the improvements.
For city or town property, report the
street number, ward, subdivision, block
and lot, etc. For rural property, report
the township, range, landmarks, etc.
Stocks and bonds. For stocks,
give:
Number of shares;
Whether common or preferred;
Issue;
Par value where needed for
valuation;
Price per share;
Exact name of corporation;
Principal exchange upon which sold,
if listed on an exchange; and
CUSIP number.
For bonds, give:
Quantity and denomination;
Name of obligor;
Date of maturity;
Principal exchange, if listed on an
exchange;
Interest rate;
Interest due date; and
CUSIP number.
If the stock or bond is unlisted, show
the company's principal business office.
The CUSIP (Committee on Uniform
Security Identification Procedure)
number is a nine-digit number assigned
to all stocks and bonds traded on major
exchanges and many unlisted
securities. Usually, the CUSIP number
is printed on the face of the stock

certificate. If the CUSIP number is not
printed on the certificate, it may be
obtained through the company's
transfer agent.
Other personal property. Any
interest in personal property involved in
a termination must be described in
enough detail that the IRS can value it.
Column d. Valuation date. Unless
you elected alternate valuation by
checking the box on line 3 of
Schedule A, the valuation date should
be the same as the termination date.
Column e. Value. Reduce the value of
any property being reported on
Schedule A by the amount of any
consideration provided by the skip
person.
Explain how the values reported in
column e were figured and attach
copies of any appraisals.

Schedules B(1) and B(2)

To figure the taxable amount for a
taxable termination, you may deduct
expenses similar to those deductible
under section 2053 from the value of the
property subject to the termination.

Schedule B(1)—General Trust
Debts, Expenses, and Taxes

Report here only those expenses
related to the entire trust. Examples of
such expenses are trustee's fees,
administrative expenses, financial
advisor's fees, and accounting fees.
Column a. Item no. Assign an item
number to each separate expense.
These will not necessarily correspond
with the item numbers on Schedule A.
Column b. Description. List the
names and addresses of persons to
whom the expenses are payable and
describe the nature of the expenses.

Column c. Amount. Enter here the
entire amount of the expense for the tax
year for which the return is being filed.
Line 2. Figure the percentage of
expense to allocate to the property
involved in the termination as follows.
1. Divide the value of the interest
that has been terminated by the total
value of the trust at the time of the
termination; and
2. Multiply the result by a fraction,
the numerator of which is the number of
days in the year through the date of the
termination, and the denominator of
which is the total number of days in the
year (or, if the entire trust was
terminated during the year, the total
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number of days the trust was in
existence during the year).
If there is more than one termination
during the year, you must reduce the
total expense used in the allocation by
the expense allocated to the prior
terminations. For example, assume that
the total administrative expense for the
year was $1,000 and $300 was
allocated to the first termination. The
expense allocated to the second
termination would be a percentage of
$700, not of the entire $1,000.

Schedule B(2)—Specific
Termination-Related Debts,
Expenses, and Taxes

Report here only those expenses
related solely to the interest that has
terminated. Examples of these
expenses are property tax on real
estate, the cost of selling property, or
attorney's fees for defending the title to
property.

Column a. Item no. Assign an item
number to each separate expense. This
will not necessarily correspond with the
item numbers on Schedule A.
Column b. Description. List the
names and addresses of persons to
whom the expenses are payable and
describe the nature of the expense. List
the item number(s) from Schedule A to
which the expense relates.
Column c. Amount. If the expense
relates to more property than that
involved in the termination but less than
the entire trust, enter in column c only
the amount attributable to the property
involved in the termination. Determine
this amount by multiplying the total
expense times a fraction. The
numerator of the fraction is the value of
the property involved in the termination
and to which the expense relates. The
denominator is the total value of the
property to which the expense relates.

Schedule A (Lines 5–10)
Line 7. Inclusion Ratio

The trustee must figure the inclusion
ratio for every termination. All
terminations, or any parts of a single
termination, that have different inclusion
ratios must be shown on separate
Schedules A. Identify the separate
trusts by Schedule A number when
showing your inclusion ratio calculation.
The inclusion ratio is the excess of 1
over the applicable fraction determined
for the trust in which the termination
occurred.

Applicable fraction. The applicable
fraction is a fraction, the numerator of
which is the amount of the GST
exemption. The denominator of the
fraction is:
1. The value of the property
transferred to the trust, minus
2. The sum of:
a. Any federal estate tax or state
death tax actually recovered from the
trust attributable to the property, and
b. Any charitable deduction allowed
under section 2055 or 2522 with respect
to the property.
Round the applicable fraction to at
least the nearest one-thousandth (for
example,“.001”).
Numerator. GST exemption. Every
individual settlor is allowed a lifetime
GST exemption against property that
the individual has transferred. For
generation-skipping transfers made
through 1998, the amount of the
exemption was $1 million. The GST
exemption amounts for 1999 through
2014 are as follows:
Year of Transfer
1999 . . . . . . . . . . .
2000 . . . . . . . . . . .
2001 . . . . . . . . . . .
2002 . . . . . . . . . . .
2003 . . . . . . . . . . .
2004 and 2005 . . . . .
2006, 2007, and 2008
2009 . . . . . . . . . . .
2010 and 2011 . . . . .
2012 . . . . . . . . . . .
2013 . . . . . . . . . . .
2014 . . . . . . . . . . .

. .
. .
. .
. .
. .
. .
. .
. .
. .
. .
. .
. .

GST
exemption
$1,010,000
$1,030,000
$1,060,000
$1,100,000
$1,120,000
$1,500,000
$2,000,000
$3,500,000
$5,000,000
$5,120,000
$5,250,000
$5,340,000

For existing trusts, transferors may
allocate the additional GST exemption
amount attributable to indexing
adjustments if they otherwise qualify
under the existing rules for late
allocations. For more information, see
section 2632 and Multiple transfers,
later.
Once made, allocations are
irrevocable.
Allocation of the GST exemption is
made by the settlor on Form 709 or on
Form 706 by the executor of the settlor's
estate. Therefore, you should obtain
information regarding the allocation of
the exemption to this trust from the
settlor or the executor of the settlor's
estate, as applicable.

If the settlor's entire GST exemption
is not allocated by the due date
(including extensions) of the settlor's
estate tax return, the exemption is
automatically allocated to the settlor's
generation-skipping transfers under the
rules of section 2632.
Denominator. Valuation of trust assets. In general, for an inter vivos
transfer, you should use the gift tax
value in the denominator of the
applicable fraction as long as the
allocation of the GST exemption was
made on a timely filed gift tax return or
was deemed made under section
2632(b)(1).
If the allocation of the exemption to
an inter vivos transfer is not made on a
timely filed gift tax return and is not
deemed made under section 2632(b)
(1), the value for purposes of the
applicable fraction is the value of the
property transferred at the time the
allocation under section 2632(a) is filed
with the IRS.
The value of a testamentary transfer
is generally the estate tax value.
For qualified terminable interest
property (QTIP) that is included in the
estate of the surviving spouse of the
settlor because of section 2044, if the
surviving spouse is considered the
transferor under section 2652(a) for
GST purposes, the value is the estate
tax value in the estate of the surviving
spouse.
A special QTIP election allows
property for which a QTIP election was
made for estate or gift tax purposes to
be treated for GST tax purposes as if
the QTIP election had not been made. If
the special QTIP election has been
made, the predeceased settlor spouse
is the transferor and the value is that
spouse's estate or gift tax value under
the rules described above. The settlor
spouse or the executor of the
predeceased settlor spouse's estate
must have made the special QTIP
election.
Transfers subject to an estate tax inclusion period. If a transferor made an
inter vivos transfer, and the property
transferred would have been includible
in the transferor's estate if he or she had
died immediately after the transfer
(other than by reason of the transferor
dying within 3 years of making the gift),
for purposes of determining the
inclusion ratio, an allocation of GST
exemption will only become effective at
the close of the estate tax inclusion
period (ETIP).

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The value of the property for the
purpose of figuring the inclusion ratio is
the estate tax value if the property is
includible in the transferor's gross
estate. Otherwise, the property is valued
at the close of the ETIP, provided that
the GST exemption is allocated on a
timely filed gift tax return for the
calendar year in which the ETIP closes.
The ETIP closes at the earliest of:
The time the transferred property
would no longer be includible in the
settlor's estate,
The date of a generation-skipping
transfer of the property, or
The date of death of the settlor.
If the allocation is not made on a
timely filed gift tax return, the property is
valued at the time of the late allocation.
Multiple transfers. When a transfer is
made to a pre-existing trust, the
applicable fraction must be refigured.
The numerator of the new fraction is the
sum of:
1. The exemption allocated to the
current transfer and
2. The nontax portion of the trust
immediately before the current transfer
(the product of the applicable fraction
and the value of all the property in the
trust immediately before the current
transfer).
The denominator of the new fraction
is the sum of:
1. The value of the current transfer
(minus any federal estate tax or state
death tax actually paid by the trust
attributable to such property and any
charitable deduction allowed for such
property) and
2. The value (determined under the
rules described above) of all property in
the trust immediately before the current
transfer.
To figure the inclusion ratio, use only
the value of the total additions made to
the trust after October 22, 1986.
Charitable lead annuity trusts. For
termination of an interest in a charitable
lead annuity trust, the numerator of the
applicable fraction is the adjusted GST
exemption as defined below. The
denominator is the value of the trust
immediately after the termination of the
charitable lead annuity interest.
The adjusted GST exemption is the
sum of:
1. The exemption allocated to the
trust and
2. Interest on the exemption
determined at the interest rate used to
figure the estate or gift deduction for the

charitable lead annuity and for the
actual period of the charitable lead
annuity.
In the case of a late allocation, the
amount of interest accrued prior to the
date of allocation is zero.

Line 8

Enter, from the table below, the
applicable tax rate at the time the
generation-skipping transfer occurred.

Table of Maximum Tax Rates

If the generation-skipping
transfer occurred
After December 31, 2002,
but before January 1,
2004 . . . . . . . . . . . . .
After December 31, 2003,
but before January 1,
2005 . . . . . . . . . . . . .
After December 31, 2004,
but before January 1,
2006 . . . . . . . . . . . . .
After December 31, 2005,
but before January 1,
2007 . . . . . . . . . . . . .
After December 31, 2006,
but before January 1,
2010 . . . . . . . . . . . . .
After December 31, 2009,
but before January 1,
2011 . . . . . . . . . . . . .
After December 31, 2010,
but before January 1,
2013 . . . . . . . . . . . . .
After December 31,
2012 . . . . . . . . .

The
maximum
tax rate is

Part III—Tax Computation
Line 9b

If you have more than six Schedules A
attached to this form, enter the total
GST tax from all Schedules A in excess
of six.

Line 12

Make checks payable to the “United
States Treasury.” Please write the trust's
EIN, the year of the transfer, and “Form
706-GS(T)” on the check to ensure
posting to the proper account. Enclose,
but do not attach, the payment with
Form 706-GS(T).

49%
.

48%
.

47%
.

46%
.

45%
.

0%
.

35%
.

40%
. . . . .

Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the
United States. You are required to give us the information. 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.
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the form displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long
as their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return
information are confidential, as required by section 6103.
is:

The time needed to complete and file this form will vary depending on individual circumstances. The average estimated time

Form
706-GS(T)
Schedule A
Schedule B

Recordkeeping

Learning about the law
or the form

Preparing the form

39 min.
13 min.
13 min.

32 min.
13 min.
9 min.

32 min.
37 min.
19 min.

Copying, assembling,
and sending the form to
the IRS
20 min.
20 min.
20 min.

If you have comments concerning the accuracy of these estimates or suggestions for making this form simpler, we would be
happy to hear from you. You can send us comment at www.irs.gov/formspubs/. Click on “More Information” and then on “Give
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