U.S. Estate Tax Return for Qualified Domestic Trusts

Instructions for
Form 706-QDT

Department of the Treasury
Internal Revenue Service

(Rev. June 2019)

U.S. Estate Tax Return for Qualified Domestic Trusts
Section references are to the Internal Revenue
Code unless otherwise noted.

Future Developments

For the latest information about
developments related to Form 706-QDT
and its instructions, such as legislation
enacted after they were published, go to
IRS.gov/Form706QDT.

What's New
New filing address. Effective January
1, 2019, Form 706-QDT will be filed in
Kansas City, Missouri. See Where To
File, later.

Reminders
Expanded definition of spouse. For
federal tax purposes, individuals of the
same sex are considered married if they
were lawfully married in a state (or
foreign country) whose laws authorize
the marriage of two individuals of the
same sex, even if the state (or foreign
country) in which they now live does not
recognize same-sex marriage. The term
“spouse” includes an individual married
to a person of the same sex if the couple
is lawfully married under state (or
foreign) law. See Rev. Rul. 2013-17,
2013-38 I.R.B. 201, available at Rev.
Rul. 2013-17, for more details.

General Instructions
Purpose of Form

The trustee or designated filer
(described below) of a qualified
domestic trust (QDOT) uses Form
706-QDT to figure and report the estate
tax due on:
• Certain distributions from the QDOT,
• The value of the property remaining in
the QDOT on the date of the surviving
spouse's death, and
• The corpus portion of certain annuity
payments.
Under certain circumstances, the
trustee/designated filer uses Form
706-QDT to notify the IRS that the trust
is exempt from future filing because the
surviving spouse has become a U.S.
citizen and meets the requirements
listed under Part II—Elections by the
May 28, 2019

Trustee/Designated Filer, Line 4.
Spousal election, later.
The QDOT rules apply only in those
situations where a decedent's surviving
spouse is not a U.S. citizen.

Who Must File

Either the trustee or the designated filer,
as described below, must file Form
706-QDT for any year in which the
QDOT has a taxable event (defined
below) or makes a distribution on
account of hardship.

Trustee

If the surviving spouse is the beneficiary
of only one QDOT, the trustee of that
QDOT is liable for filing Form 706-QDT
and paying the tax.
The trustee must also file Form
706-QDT if the surviving spouse is the
beneficiary of more than one QDOT,
unless the decedent's executor
designated one U.S. trustee as the
designated filer.
If there is more than one trustee for
any single trust, each trustee is liable for
filing the return and paying the tax.
If there is a designated filer, the
trustee must still complete a separate
Schedule B of Form 706-QDT for each
trust for which he or she is the trustee
and provide the completed Schedule B
to the designated filer at least 60 days
before the due date for filing Form
706-QDT.

Designated Filer

If the surviving spouse is the beneficiary
of more than one QDOT from a single
decedent, and the decedent's executor
has made such a designation, then the
designated filer selected by the
executor is liable for filing the return and
paying the tax for all QDOTs. This
designation can be made on either the
decedent's estate tax return or the first
Form 706-QDT that is timely filed.
In this case, the trustee of each
QDOT is responsible for completing
Schedule B of Form 706-QDT for his or
her trust and giving it to the designated
filer.
Cat. No. 12384F

Definitions
Qualified domestic trust. A qualified
domestic trust (QDOT) is any trust that
qualifies for an estate tax marital
deduction under section 2056 and also
meets all of the following requirements.
• The trust instrument requires that at
least one trustee be either a U.S. citizen
or a domestic corporation.
• The trust instrument requires that no
distribution of corpus from the trust may
be made unless the trustee who is a
U.S. citizen or a domestic corporation
has the right to withhold from the
distribution the QDOT tax imposed on
the distribution.
• The QDOT election under section
2056A(d) has been made for the trust
by the executor of the estate on the
decedent's estate tax return.
• The requirements of all applicable
regulations have been met.
Taxable event. A taxable event is any
of the following.
1. Any distribution from a QDOT
(and certain annuity payments) before
the death of the surviving spouse,
except:
a. Distributions of income to the
surviving spouse, and
b. Any distributions made to the
surviving spouse on account of
hardship.
2. The death of the surviving
spouse.
3. The failure of the trust to qualify
as a QDOT.
Hardship distribution. A distribution
of principal is treated as made on
account of hardship if it is made to the
spouse from the QDOT in response to
an immediate and substantial financial
need relating to the spouse's health,
maintenance, education, or support, or
the health, maintenance, education, or
support of any person that the surviving
spouse is legally obligated to support.
Decedent. In these instructions,
decedent means the grantor of the
QDOT on whose estate tax return the
executor makes the QDOT election.

Surviving spouse. In these
instructions, surviving spouse means
the individual who is both the surviving
spouse of the decedent and also the
beneficiary of the decedent's QDOT.

When To File

Form 706-QDT is an annual return.
Generally, the return to report
distributions is due on or after January 1
but not later than April 15 of the year
following any calendar year in which a
taxable event occurred or a distribution
was made on account of hardship.

However, if you are filing the return
because of the death of the surviving
spouse, you must file it within 9 months
following the date of death. You must
also report on that return all reportable
distributions made during the calendar
year in which the surviving spouse died.
This rule may result in a return being
due before April 15. For example, if the
surviving spouse died on June 14,
2019, Form 706-QDT would be due
March 14, 2020, and must include all
reportable distributions made during
2019.
If the trust ceases to qualify as a
QDOT, you must file Form 706-QDT
within 9 months of the date on which the
trust ceased to qualify. You must
include on that return any reportable
distributions made during the calendar
year of the failure to qualify.

Where To File

Effective January 1, 2019, file Form
706-QDT at the following address.
Department of the Treasury
Internal Revenue Service Center
Kansas City, MO 64999
If using a PDS, use this address.
Internal Revenue Submission
Processing Center
333 W. Pershing
Kansas City, MO 64108

Paying the Tax

Generally, the QDOT estate tax is due
by April 15 of the year following the
calendar year in which taxable
distributions were made. However, if the
surviving spouse died during the year or
if the trust ceased to qualify as a QDOT
during the year, the tax on those events
and on any taxable distributions
occurring during that calendar year is
due within 9 months following the date
of death or the failure to qualify.
If the QDOT qualifies, you may elect
under section 6166 to pay the tax in
installments. You may make either a
protective or final election by checking
“Yes” on line 3 of Part II—Elections by
the Trustee/Designated Filer, and
attaching the required statements. See
the instructions under Line 3.
Installment payments, later, for
additional information.

Use Form 4768, Application for
Extension of Time To File a Return
and/or Pay U.S. Estate (and
Generation-Skipping Transfer) Taxes, to
apply for an automatic 6-month
extension of time to file Form 706-QDT.
Check the “Form 706-QDT” box in Part
II of Form 4768.

Make the check payable to “United
States Treasury.” Write the surviving
spouse's social security number (SSN)
(or individual taxpayer identification
number (ITIN), if applicable) and “Form
706-QDT” on the check to assist us in
posting it to the proper account.

Note. An extension of time to file does
not extend the time to pay the tax.

If the trustee is filing the return and there
is more than one trustee listed, all listed
trustees must verify the return. All
trustees are responsible for the return
as filed and are liable for penalties
provided for erroneous or false returns.

Private delivery services (PDSs).
You can use certain PDSs designated
by the IRS to meet the "timely mailing as
timely filing/paying" rule for tax returns
and payments. Go to IRS.gov/PDS for
the current list of designated services.
The PDS can tell you how to get
written proof of the mailing date.
For the IRS mailing address to use if
you’re using a PDS, go to IRS.gov/
PDSStreetAddresses.
PDSs can’t deliver items to P.O.
boxes. You must use the U.S
CAUTION Postal Service to mail any item
to an IRS P.O. box address.

!

Signature(s)

The trustee/designated filer who files
the return must, in every case, sign the
declaration on page 1 under penalties of
perjury. The trustee/designated filer
may use Form 2848, Power of Attorney
and Declaration of Representative, to
authorize another person to act for him
or her before the IRS.

Paid Preparer Use Only

Generally, anyone who is paid to
prepare the return must sign the return
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in the space provided and fill in the Paid
Preparer Use Only area.
A paid preparer cannot use a social
security number in the Paid Preparer
Use Only box. The paid preparer must
use a preparer tax identification number
(PTIN). In addition to signing and
completing the required information, the
paid preparer must give a copy of the
completed return to the trustee/
designated filer.

Supplemental Documents
You must attach a copy of the trust
instrument to the first Form 706-QDT
filed for the trust. You do not need to
attach a copy of the trust to any
subsequent filings of Form 706-QDT.

If you are filing the return due to the
death of the surviving spouse, attach a
copy of the death certificate.

Penalties

Section 6651 provides 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.
Section 6662 provides penalties for
underpayment of estate taxes which
exceed $5,000 that are attributable to
valuation understatements. See
sections 6662(g) and (h) for more
details.
Return preparer. Estate tax return
preparers who prepare any return or
claim for refund that reflects an
understatement of tax liability due to an
unreasonable position are subject to a
penalty equal to the greater of $1,000 or
50% of the income earned (or to be
earned) for the preparation of each such
return. Estate tax return preparers who
prepare any return or claim for refund
that reflects an understatement of tax
liability due to willful or reckless conduct
are subject to a penalty of $5,000 or
75% of the income derived (or income
to be derived), whichever is greater, for
the preparation of each such return. See
section 6694, the related regulations,
and Announcement 2009-15, 2009-11
I.R.B. 687, available at Announcement
2009-15, for more information.

Security for Payment of
the Tax
Assets in Excess of $2 Million

If the estate tax value of the assets
passing to the QDOT exceeds $2
million (determined without regard to
any indebtedness), the trust instrument
must require that the trust meet at least

one of the following conditions at all
times during the term of the QDOT.
• At least one U.S. trustee must be a
bank as defined in section 581.
• The U.S. trustee must furnish a bond
in favor of the IRS in an amount equal to
65% of the fair market value (FMV) of
the trust assets.
• The U.S. trustee must furnish an
irrevocable letter of credit issued by a
bank in an amount equal to 65% of the
FMV of the trust assets.
The trust instrument may also meet
this requirement by specific reference to
the applicable paragraph of Regulations
section 20.2056A-2(d).
The QDOT may alternate between
any of these arrangements provided
that one of the arrangements is
operative at any given time. The QDOT
may give the trustee the discretion to
use any one of the security
arrangements, or may limit the trustee to
using only one or two of the
arrangements.

Assets of $2 Million or Less

If the estate tax value of the assets
passing to the QDOT is $2 million or
less (determined without regard to any
indebtedness), the trust instrument must
require that the trust meet at least one of
the following conditions at all times
during the term of the QDOT.
• No more than 35% of the FMV of trust
assets, determined annually on the last
day of the tax year of the trust, will
consist of real property located outside
the United States.
• The trust will meet the requirements
described above for QDOTs with assets
in excess of $2 million.
For this purpose, if more than one
QDOT is established for the benefit of
the surviving spouse, the value of all of
the QDOTs is aggregated in
determining whether the $2 million
threshold is exceeded.

Personal Residence

For the purpose of (1) figuring the $2
million threshold, and (2) determining
the amount of any bond or letter of
credit, the executor of the decedent's
estate may elect to exclude up to
$600,000 in the value of real property
that meets the following requirements.
• It is used by or held for the use of the
surviving spouse as a personal
residence.
• It is owned directly by the QDOT.
• It passed or was treated as passing to
the QDOT under the rules for the marital
deduction when the surviving spouse is
not a U.S. citizen (section 2056(d)(2)
(B)).

The $600,000 may include the value
of any related furnishings.
Either election may have been made
by the executor on the estate tax return
for the decedent's estate. The election
to exclude the personal residence
amount from the amount of the bond or
letter of credit may also be made
prospectively by the U.S. trustee by
attaching a statement to Form 706-QDT
claiming the exclusion. This election,
whether made by the executor or by a
trustee, may be canceled by attaching
such a statement to Form 706-QDT.

Filing a Bond or Letter of Credit
If the bond or letter of credit
arrangement is selected, the executor
must have filed the bond or letter of
credit with the Form 706 or 706-NA on
which the QDOT election is made.

The U.S. trustee must provide a
written statement with the bond or letter
of credit listing the assets that will fund
the QDOT, the values of the assets, and
whether any exclusion for a personal
residence is being claimed.

Additional Information

For more information, including
additional requirements for a bond and
letter of credit, details on the exclusion
of a personal residence, rules on the
disallowance of the marital deduction for
substantial undervaluation of QDOT
property, rules regarding foreign real
property, and certain annual reporting
requirements (concerning ownership of
foreign real property, cessation of use of
a personal residence, and look-through
rules applied to the ownership of foreign
real property), see Regulations section
20.2056A-2(d).

How To Complete Form
706-QDT
Trustee Filing the Return

If the trustee is filing the complete
return, prepare it in the following order.
1. Part I—General Information on
page 1.
2. Part II—Elections by the Trustee/
Designated Filer on page 1.
3. All of Schedule B (but only lines
1a and 1b of Part I).
4. Schedule A.
5. Part III—Tax Computation on
page 1.
Enter only the totals from Parts II
through VI of Schedule B in the
corresponding “Total” lines of
Schedule A.
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Trustee Completing Schedule B
Only
If a designated filer will file the return,
the trustee must complete all applicable
parts of Schedule B for his or her
respective trust and provide it to the
designated filer at least 60 days before
the due date for filing Form 706-QDT.

Designated Filer Filing the
Return

The designated filer must receive a
completed Schedule B from the trustee
of every QDOT that has had a
reportable event or a hardship
distribution during the tax year. The
designated filer would then summarize
these on Schedule A.

Complete the return in the following
order.
1. Part I—General Information on
page 1.
2. Part II—Elections by the Trustee/
Designated Filer on page 1.
3. Schedule A.
4. Part III—Tax Computation on
page 1.
Attach each Schedule B to the return
when you file it.
If there is not enough space on a
schedule to list all the items, attach an
additional sheet of the same size to the
back of the schedule.

Rounding Off to Whole Dollars

You may round off cents to whole
dollars on the return and schedules. If
you do round to whole dollars, you must
round all amounts. To round, drop
amounts under 50 cents and increase
amounts from 50 cents to 99 cents to
the next dollar. For example, $1.39
becomes $1 and $2.50 becomes $3.

Specific Instructions
Part I—General
Information
If trustee files entire return—Lines
2a, 2b, and 2c. If the trustee is filing
the entire return, enter the trustee's
information on lines 2a, 2b, and 2c.
Line 2b. If the trustee/designated filer
is an individual, enter his or her SSN.
Otherwise, enter the employer
identification number (EIN) of the
trustee/designated filer.
Line 2c. Enter the address at which
you wish to receive correspondence
from the IRS regarding this return. This
must be an address for the designated

filer, or if the trustee is filing the return,
one of the individual trustees who is a
U.S. citizen or a trustee that is a
domestic corporation.
Line 3b. Enter the taxpayer
identification number (TIN) of the
surviving spouse. The TIN is the SSN or
ITIN.
Line 4a. Enter the name of the
decedent on whose estate tax return the
QDOT election was made.
Line 4b. Enter the SSN of the decedent
or, if applicable, the number previously
assigned to the decedent's estate by the
service center.

Part II—Elections by the
Trustee/Designated Filer

If this return is being filed because of the
death of the surviving spouse, and any
property remaining in the QDOT at that
time is includible in the estate of the
surviving spouse (or would be includible
if the surviving spouse had been a U.S.
citizen or resident), then the trustee/
designated filer may elect to apply
certain estate tax benefits on this return,
provided the estate of the surviving
spouse would be eligible for these
benefits.

Line 1. Alternate valuation. Unless
you elect at the time you file this return
to adopt alternate valuation under
section 2032, then you must value all
property of all trusts listed on
Schedule A, Part III, on the date of the
surviving spouse's death.
Note. You may not elect alternate
valuation for any property reported on
Schedule A, Parts I and II.
You may not elect alternate valuation
unless the election will decrease both
the value of the Schedule A, Part III
property, and the net tax due on the
return.
A designated filer filing for multiple
trusts must make this election for all of
the Schedule A, Part III property in all of
the trusts, taken as a whole. The
election cannot be made unless the
requirements are met for all of the
property.
You elect alternate valuation by
checking “Yes” on line 1 and filing Form
706-QDT. Once made, the election is
irrevocable.
If you elect alternate valuation, you
must value all of the property to which
the election applies as of the applicable
date as follows.
1. Any property distributed, sold,
exchanged, or otherwise disposed of by

any method within 6 months after the
surviving spouse's death is valued on
the date of distribution, sale, exchange,
or other disposition, whichever occurs
first. Value the property on the date title
passed as a result of the sale,
exchange, or other disposition.
2. Any property not distributed, sold,
exchanged, or otherwise disposed of
within the 6-month period is valued on
the date 6 months after the date of the
surviving spouse's death.
3. Any property that is “affected by
mere lapse of time” is valued as of the
date of the surviving spouse's death.
However, you may change the date of
death value to account for any change
in value that is not due to “mere lapse of
time” on the date of its distribution, sale,
exchange, or other disposition.
For additional details, see Part
3—Elections by the Executor in the
separate Instructions for Form 706.
Line 2. Special use valuation of section 2032A. Under section 2032A, you
may elect to value certain farm and
closely held business real property at its
farm or business use value rather than
its FMV. You may elect both special use
valuation and alternate valuation. To
elect this valuation, you must check
“Yes” on line 2 and complete and attach
Schedule A-1 of Form 706 and its
required additional statements.
You must file Schedule A-1 of
Form 706 and its required
CAUTION attachments with Form
706-QDT for this election to be valid.

!

The total value of the property valued
under section 2032A may not be
decreased from FMV by more than
$1,160,000 for decedents dying in
2019. For later years, the IRS will
publish the amount in an annual
revenue procedure.
Real property may qualify for the
section 2032A election if:
1. The real property is located in the
United States,
2. The real property is used for
farming or in a trade or business,
3. The real property was acquired
from or passed from the surviving
spouse to a qualified heir of the
surviving spouse,
4. The real property was owned and
used in a qualified manner by the
surviving spouse or a member of the
surviving spouse's family for 5 of the 8
years before the surviving spouse's
death, and

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5. The qualified property is the
percentage of the surviving spouse's
gross estate specified in section 2032A.
For definitions and additional
information, see section 2032A and the
related regulations. Also see the Form
706 instructions for Part 3—Elections by
the Executor and the Instructions for
Schedule A-1 within the Form 706 itself.
Line 3. Installment payments. If the
gross estate includes an interest in a
closely held business, you may be able
to elect to pay part of the estate tax in
installments under section 6166.
The maximum amount that can be
paid in installments is that part of the
estate tax that is attributable to the
closely held business. See Determine
how much of the estate tax may be paid
in installments under section 6166
under Line 3. Section 6166 Installment
Payments in the separate Instructions
for Form 706. In general, that amount is
the amount of tax that bears the same
ratio to the total estate tax that the value
of the closely held business included in
the gross estate bears to the adjusted
gross estate.
If you check this line to make a
protective election, you should attach a
notice of protective election as
described in Regulations section
20.6166-1(d). If you check this line to
make a final election, you should attach
the notice of election described in
Regulations section 20.6166-1(b).
In computing the adjusted gross
estate under section 6166(b)(6) for
purposes of determining whether an
election may be made under section
6166, the net amount of any real estate
in a closely held business must be used.
For definitions and additional
information, see section 6166 and the
related regulations. Also see the Form
706 instructions for Part 3—Elections by
the Executor and Line 3. Section 6166
Installment Payments for a chart on how
to calculate the amount of tax which
may be paid in installments under
section 6166.
Bond or lien. The IRS may require that
an estate furnish a surety bond when
granting the installment payment
election. In the alternative, the executor
may consent to elect the special lien
provisions of section 6324A in lieu of the
bond. The IRS will contact you
regarding the specifics of furnishing the
bond or electing the special lien. The
IRS will make this determination on a
case-by-case basis, and you may be
asked to provide additional information.

If you elect the lien provisions,
section 6324A requires that the lien be
placed on property having a value equal
to the total deferred tax plus 4 years of
interest. The property must be expected
to survive the deferral period, and does
not necessarily have to be property of
the estate. In addition, all of the persons
having an interest in the designated
property must consent to the creation of
this lien on the property pledged.
Line 4. Spousal election. If the
surviving spouse has become a U.S.
citizen, the QDOT tax will not apply to
any distributions made after the
surviving spouse became a citizen as
long as either:
• The surviving spouse had been a
U.S. resident at all times after the death
of the decedent and before becoming a
citizen, or
• No QDOT tax had been imposed on
any distributions prior to the surviving
spouse becoming a citizen.
You should file a final Form 706-QDT
to notify the IRS that the QDOT tax no
longer applies for this reason.
If the surviving spouse does not meet
either of the conditions above, the
QDOT tax will still not apply to
distributions after he or she becomes a
citizen if the surviving spouse elects
both:
• To treat any distributions that were
subject to QDOT tax as taxable gifts for
purposes of determining the estate or
gift tax under sections 2001 and 2501,
respectively, for the year the surviving
spouse became a citizen and all
subsequent years; and
• To treat any of the decedent's unified
credit (applicable credit amount) that
was used to reduce the QDOT tax on
taxable distributions as use of the
surviving spouse's own unified credit for
purposes of determining the spouse's
available unified credit under section
2505 for the year he or she became a
citizen and for all subsequent years.
To make these elections, check
“Yes” on line 4 and attach notification of
the election to this return.

Schedule B
Part I—General Information

If the trustee is filing the entire return,
the trustee needs to complete only lines
1a and 1b of this part of Schedule B (but
all of Parts II through VI). When
completing Part I on page 1, enter the
remaining trustee's information on lines
2a, 2b, and 2c.
Line 1b. All trusts filing Form 706-QDT
must have an EIN. If you don’t have an

EIN, you may apply for one online by
visiting the IRS website at IRS.gov/EIN.
You may also apply for an EIN by faxing
or mailing Form SS-4 to the IRS. If the
EIN has not been received by the filing
time for Form 706-QDT, write “Applied
for” on line 1b.
Line 2a. You must enter on this line
either the name of an individual trustee
who is a U.S. citizen or a trustee that is
a domestic corporation. If there is more
than one trustee, enter the one to be
contacted by the IRS. List the names of
all additional trustees on a sheet of
paper attached to this return. Include
the SSN or EIN of all U.S. citizens or
domestic corporations.
Line 2b. Enter the SSN or EIN, as
applicable, of the trustee listed on
line 2a.

Part II—Taxable Distributions
From Prior Years

Enter here the total of all taxable
distributions that were or should have
been reported on previously filed Forms
706-QDT.

Part III—Current Taxable
Distributions

Enter here the total amount of corpus
distributed during the calendar year or
other period covered by this return and
before the date of death of the surviving
spouse. Include as a distribution on this
line any QDOT estate tax paid during
the calendar year out of the QDOT.
Include all distributions even if the
hardship exemption is being claimed.
Also, include as distributions in this
part any reportable payments to the
surviving spouse from nonassignable
annuities and other arrangements when
the executor has filed with the estate tax
return for the decedent's estate an
agreement to pay section 2056A estate
tax on such distributions. For details,
see Regulations section 20.2056A-4(c).

Column a. Date of distribution. The
date of distribution is the date on which
the title to the distributed property
passed from the trustee to the surviving
spouse.
Column b. Description. Include in the
description the name of the individual(s)
to whom the distribution was made.
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 location and, if the parcel is
improved, describe the improvements.
For city or town property, report the
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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 (defined below).
For bonds, give:
• Quantity and denomination;
• Name of obligor;
• Date of maturity;
• Interest rate;
• Interest due date;
• Principal exchange, if listed on an
exchange; 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 that is
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
personal property distributed must be
described in enough detail that its value
can be ascertained by the IRS.
Column c. Value. The value of a
distribution is its FMV on the date of
distribution. FMV is the price at which
the property would change hands
between a willing buyer and a willing
seller, when neither is forced to buy or
to sell, and both have reasonable
knowledge of all the relevant facts. FMV
may not be determined by a forced sale
price, nor by the sale price of the item in
a market other than that in which the
item is most commonly sold to the
public. The location of the item must be
taken into account whenever relevant.
Stocks and bonds. The FMV of a
stock or bond (whether listed or
unlisted) is the mean between the
highest and lowest selling prices quoted
on the valuation date. If only the closing
selling prices are available, then the
FMV is the mean between the quoted
closing selling price on the valuation

date and on the trading day before the
valuation date. If there were no sales on
the valuation date, figure the FMV as
follows.
1. Find the mean between the
highest and lowest selling prices on the
nearest trading day before and the
nearest trading day after the valuation
date. Both trading days must be
reasonably close to the valuation date.
2. Prorate the difference between
the mean prices to the valuation date.
3. Add or subtract (whichever
applies).
See the instructions for Schedule B
of Form 706 for additional information
on valuing stocks and bonds.
Column d. Amount of hardship exemption claimed. Distributions to the
surviving spouse on account of hardship
are exempt from the QDOT tax. Enter in
column d the amount of any distribution
for which the hardship exemption is
being claimed. Do not enter any amount
here that has not been included in the
amount listed in column c. Also, if the
surviving spouse is the beneficiary of
more than one QDOT, you may not
claim the hardship exemption unless the
decedent's executor selected a
designated filer. See Designated Filer,
earlier.

Part IV—Taxable Property in
Trust at Death of Surviving
Spouse

You must report in Part IV all property
remaining in the QDOT on the date of
death of the surviving spouse (or the
date the trust failed to qualify as a
QDOT, if applicable). This includes both
corpus and undistributed income.
Interest accrued to the date of the
surviving spouse's death on bonds,
notes, and other interest-bearing
obligations is property of the QDOT on
the date of death. Rent accrued to the
date of the surviving spouse's death on
leased real and personal property is
property of the QDOT on the date of
death.
Outstanding dividends that were
declared to stockholders of record on or
before the date of the surviving
spouse's death are considered property
of the QDOT on the date of death.
Ordinary dividends declared to
stockholders of record after the date of
the surviving spouse's death are not
property of the QDOT on the date of
death. However, if you have elected
alternate valuation on line 1 of Part II,
page 1, and dividends are declared to
stockholders of record after the date of

the surviving spouse's death so that the
shares of stock at the later valuation
date do not reasonably represent the
same property at the date of the
surviving spouse's death, include those
dividends (except dividends paid from
earnings of the corporation after the
date of the surviving spouse's death) in
the alternate valuation.
If there is not enough space to list all
of the property, attach additional sheets
of the same size, using the same format
as Part IV.
Column a. Item no. Assign a separate
item number to each separate type of
property. For example, you can include
under a single item number all stock of
the same issuer and type, but must list
separate types (for example, preferred
and common) under separate item
numbers.
Column b. Description. See the
instructions under Part III—Current
Taxable Distributions, Column b.
Description, earlier.
Column c. Alternate valuation date.
If this return involves only one trust,
enter the alternate valuation date only if
you answered “Yes” to question 1 of
Part II—Elections by the Trustee/
Designated Filer.
If the designated filer is filing this
return for multiple trusts, the individual
trustees will complete Part IV, but only
the designated filer can elect alternate
valuation. To allow the designated filer
to make this decision, the trustee must
provide on an attachment to Schedule B
both the regular and the alternate value
(and the alternate valuation date) for all
assets, unless the designated filer has
notified the trustee that this is not
required.
Column d. Value. See the instructions
under Part III—Current Taxable
Distributions, Column c. Value, earlier.

Parts V and VI—Marital and
Charitable Deductions

Marital and charitable deductions are
allowable for any property that both
remained in the QDOT on the date of
the surviving spouse's death and was
includible in the gross estate of the
surviving spouse (or would have been
includible if the surviving spouse had
been a U.S. citizen or resident).
Do not make an entry in Parts V and
VI unless there is an entry in Part IV of
Schedule B. Also, the sum of the total of
the amounts entered in Parts V and VI
cannot exceed the total of the amount
entered in Part IV of Schedule B.
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For details on the marital and
charitable deductions, see the
instructions for Schedule M and
Schedule O of Form 706, as applicable.

Schedule A

When a designated filer is filing Form
706-QDT for more than one trust, use
Schedule A to summarize the
Schedule B amounts provided by the
trustees. Under “EIN of QDOT” (that is,
column a of Parts II, III, and IV), enter
the EIN of the appropriate trust. If the
trustee is filing the return, simply
transfer the totals from Schedule B to
the corresponding “Total” lines on
Schedule A.

Part III—Tax Computation
(Page 1 of Form 706-QDT)
Line 7. Enter the amount of the taxable
estate from one of the following as filed
for the decedent's estate or as finally
determined by the IRS.
• Part 2—Tax Computation, line 3 of
Form 706 (for estates of decedents
dying before January 1, 2005).
• Part 2—Tax Computation, line 3c of
Form 706 (for estates of decedents
dying on or after January 1, 2005).
• Part II—Tax Computation, line 1 of
Form 706-NA.
Lines 10 and 11. Using the same
revision of Form 706 or Form 706-NA on
which the executor filed the decedent's
estate tax return, recompute the
decedent's net estate tax by substituting
the amounts on line 9 and line 8 of this
Form 706-QDT for the decedent's
taxable estate from one of the following.
• Part 2—Tax Computation, line 3 of
Form 706 (for estates of decedents
dying before January 1, 2005).
• Part 2—Tax Computation, line 3c of
Form 706 (for estates of decedents
dying on or after January 1, 2005).
• Part II—Tax Computation, line 1 of
Form 706-NA.
Prior year versions of Forms 706 and
706-NA can be obtained by calling
800-TAX-FORM (800-829-3676) or by
accessing the IRS website at
IRS.gov.
Note that as a result of the
recomputation, some items other than
the taxable estate might be different
from what was on the decedent's actual
estate tax return. If the decedent's
estate did not fully use its unified credit,
additional unified credit may be
allowable in the recomputation.
If the decedent's estate claimed a
credit for tax on prior transfers and the
credit was limited by section 2013(c),

the recomputed credit may be different
than on the return as filed.
Also, if the decedent's estate claimed
a credit for state death taxes (for
decedents dying before January 1,
2005) or a credit for foreign death taxes
and the amount of the credit that could
be claimed was limited by section
2011(b) (prior to its repeal on January 1,
2005) or section 2014(b), respectively,
the recomputed credit may be different.
If the final determination of the tax
due on the estate of the decedent has
not been made at the time this return is
filed, you must figure the tax on these
lines using the highest rate of tax (see
Table of Maximum Tax Rates below) in
effect at the time of the decedent's
death.
Also, if there is more than one QDOT
with respect to any decedent, you must
figure the tax on lines 10 and 11 using
the highest rate of tax (see Table of
Maximum Tax Rates below) in effect at
the time of the decedent's death unless
all of the following conditions are met.
• The decedent's executor has
designated a single person to be
responsible for filing Form 706-QDT for
all of the trusts (designated filer).
• The designated filer is either an
individual who is a U.S. citizen or is a
domestic corporation.
• The designated filer meets the
requirements of all applicable
regulations.
Further, if the return is being filed
because of the death of the surviving
spouse, then in figuring line 10, any
foreign death taxes paid by the estate of
the surviving spouse may be used in
determining the allowable credits in
recomputing the decedent's estate tax,
if all of the following conditions are met.
1. This return is being filed because
of the death of the surviving spouse.
2. Any property remaining in the
QDOT at that time is includible in the
estate of the surviving spouse (or would

be includible if the surviving spouse had
been a U.S. citizen or resident).
3. The credit is allowable (or would
be allowable if the surviving spouse had
been a U.S. citizen or resident) to the
estate of the surviving spouse with
respect to the property referred to in (2),
above.
4. The taxes were actually paid to a
foreign jurisdiction.
For details on claiming this credit,
see the Instructions for Form 706. If you
claim the foreign death tax credit, you
must complete and attach Schedule P
of Form 706.

Table of Maximum Tax Rates
The
maximum
tax rate
If the decedent died . . . . is . . . . . .

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 not required to provide the
information requested on a form that is
subject to the Paperwork Reduction Act
unless 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.
The time needed to complete and file
this form will vary depending on
individual circumstances. The estimated
average time is:
Recordkeeping . . . . .

1 hr., 12 min.

After December 31, 2004,
but before January 1, 2006

47%

Learning about the
law or the form . . . . .

42 min.

After December 31, 2005,
but before January 1, 2007

46%

Preparing the
form . . . . . . . . . . . . .

1 hr., 30 min.

After December 31, 2006,
but before January 1, 2010

45%

After December 31, 2009,
but before January 1, 2013

35%*

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

1 hr., 3 min.

After December 31, 2012

40%

* Special rules can apply for 2010. For more
information, see Pub. 4895, Tax Treatment
of Property Acquired From a Decedent
Dying in 2010.

Line 14. Make the check payable to
“United States Treasury.” Please write
the surviving spouse's SSN (or ITIN, if
applicable) and “Form 706-QDT” on the
check to assist us in posting it to the
proper account.
Paperwork Reduction Act Notice.
We ask for the information on this form

-7-

If you have comments concerning the
accuracy of these time estimates or
suggestions for making this form
simpler, we would be happy to hear
from you. You can send us comments
from IRS.gov/FormComments. Or you
can write to the Internal Revenue
Service, Tax Forms and Publications
Division, 1111 Constitution Ave. NW,
IR-6526, Washington, DC 20224. Do
not send the tax form to this address.
Instead, see Where To File, earlier.