Supporting Statement 1545-0015

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United States Estate (and Generation-Skipping Transfer) Tax Return

OMB: 1545-0015

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SUPPORTING STATEMENT

Internal Revenue Service (IRS)

Estate (and Generation-Skipping Transfer) Tax Returns and Related Forms

OMB Control Number 1545-0015


  1. CIRCUMSTANCES NECESSITATING COLLECTION OF INFORMATION


The federal estate tax is a tax on the transfer of property at death. It is applied to estates for which at-death gross assets ("gross estate") plus adjusted taxable gifts exceed the filing threshold. Chapter 11 of the Internal Revenue Code (IRC) provides the rules and requirements for estate taxes. IRC section 2001 imposes a tax on the transfer of the taxable estate of every decedent who was a citizen or resident of the United States. Chapter 13 of the IRC provides rules and requirements for certain generation-skipping transfers (GST). IRC section 2601 imposes a tax on a GST.


Form 706 and related forms are used to report and compute both taxes. IRC section 2603(a)(2) provides that the GST tax imposed on a direct skip from a trust must be paid by the trustee (not the estate).


This information collection request (ICR) covers the actual reporting burden associated with preparing and submitting the prescribed return forms, by executors required to file Form 706 series.



Form No.

Form Description

Form 706

This form is to be filed on certain estates of a deceased resident or citizen.

Form 706 Schedule A

If the total gross estate contains any real estate, complete Schedule A.

Form 706 Schedule B

If the total gross estate contains any stocks or bonds, you

must complete Schedule B.

Form 706 Schedule C

Complete Schedule C and file it with your return if the total gross estate contains any: Mortgages, Notes, or Cash.

Form 706 Schedule D

If you are required to file Form 706 and there was any insurance on the decedent's life, whether included in the gross estate, you must complete Schedule D.

Form 706 Schedule E

If you are required to file Form 706, complete Schedule E and file it with the return if the decedent owned any joint property at the time of death, whether the decedent's interest is includible in the gross estate.

Form 706 Schedule F

On Schedule F, list all items that must be included in the gross estate that are not reported on any other schedule.

Form 706 Schedule G

Complete Schedule G and file it with the return if the decedent made transfers during the decedent’s life.

Form 706 Schedule H

Complete Schedule H and file it with the return if you answered “Yes” to question 14 of Part 4—General Information.

Form 706 Schedule I

Complete Schedule l and file it with the return if you answered “Yes” to question 16 of Part 4—General Information.

Form 706 Schedule J

Complete and file Schedule J if you claim a deduction on item 14 of Part 5—Recapitulation.

Form 706 Schedule K

You must complete and attach Schedule K if you claimed deductions on either item 15 or item 16 of Part 5—Recapitulation.

Form 706 Schedule L

Complete Schedule L and file it with the return if you claim deductions on either item 19 or item 20 of Part 5—Recapitulation.

Form 706 Schedule M

You must complete Schedule M and file it with the return if you claim a deduction on item 21 of Part 5—Recapitulation.

Form 706 Schedule O

You must complete Schedule O and file it with the return if you claim a deduction on item 22 of Part 5—Recapitulation.

Form 706 Schedule P

If you claim a credit on Part 2—Tax Computation, line 13, complete Schedule P and file it with the return. Attach Form(s) 706-CE to Form 706 to support any credit you claim.

Form 706 Schedule Q

Complete Schedule Q and file it with the return if you claim a credit on Part 2—Tax Computation, line 14.

Form 706 Schedule R

Schedule R is used to figure the generation-skipping transfer (GST) tax that is payable by the estate.

Form 706 Schedule R-1

Schedule R-1 (Form 706) serves as a payment voucher for the Generation-Skipping Transfer (GST) tax imposed on a direct skip from a trust, which the trustee of the of the trust must pay.

Form 706 Schedule T

The election to value certain farm and closely held business property at its special-use value is made by checking “Yes” on Form 706, Part 3—Elections by the Executor, line 2. Schedule T is used to report the additional information that must be submitted to support this election.

Form 706 Schedule U

Schedule U covers Qualified Conservation Easement Exclusion elections.

Form 706 Schedule W

This form is used when more space is needed to list more assets or deductions than was available on one of the main schedules.

Form 706 Schedule PC

This form is used by Form 706 filers to file a section 2053 protective claim for refund by estates of decedents who died after December 31, 2011. It will also be used to inform the IRS when the contingency leading to the protective claim for refund is resolved and the refund due the estate is finalized.

Form 706-A

This form is used to report all dispositions or cessations of qualified use under Section 2032A of the Internal Revenue Code.

Form 706-CE

Executors use Form 706-CE as evidence of payment of foreign death taxes, to be allowed a credit for those foreign death taxes on Form 706.

Form 706-GS(D)

Form 706-GS(D) is used by a skip person distributee to calculate and report the tax due on distributions from a trust that are subject to the generation-skipping transfer (GST) tax.

Form 706-GS(D-1)

A trustee uses Form 706-GS(D-1) to report certain distributions from a trust that are subject to the generation-skipping transfer tax and to provide the skip person distributee with information needed to figure the tax due on the distribution.

Form 706-GS(T)

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.

Form 706-NA

Executors for nonresident alien decedents use Form 706-NA to compute estate and generation-skipping transfer (GST) tax liability. The estate tax is imposed on the transfer of the decedent's taxable estate, rather than on the receipt of any part of it.

Form 706-QDT

The trustee/designated filers of qualified domestic trusts use Form 706-QDT to figure and report tax on certain distributions, the value of property on the date of the surviving spouse's death, and the corpus portion of certain annuity payments.


  1. USE OF DATA


The IRS uses the information on Form 706 and related returns to enforce the estate and GST tax provisions of the IRC and verify that the taxes have been properly computed.


  1. USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN


Form 706 and related returns are available electronically on IRS.gov. IRS is currently working on programming to allow electronic filing of Form 706 series. We anticipate electronic filing to be enable by tax year 2026.


  1. EFFORTS TO IDENTIFY DUPLICATION


The information obtained through this collection is unique and is not already available for use or adaptation from another source.

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


There is minimal to no burden on small businesses or entities by this collection due to the inapplicability of the authorizing statues under IRC sections 2001 and 2601.


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


The IRS will use the information to determine and verify that estate and GST taxes have been properly computed. A less frequent collection would compromise the ability of the IRS to enforce tax compliance. Tax compliance is a vital part of the government’s ability to meet its mission and serve the public.


  1. 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 5 CFR 1320.5(d)(2).






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


In response to the Federal Register notice dated April 2, 2025, (90 FR 14520), the IRS received no public comments.


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


No payment or gift has been provided to any respondents.


  1. ASSURANCE OF CONFIDENTIALITY OF RESPONSES


Generally, tax returns and tax return information are confidential as required by 26 U.S.C. 6103.


  1. JUSTIFICATION OF SENSITIVE QUESTIONS


A privacy impact assessment (PIA) has been conducted for information collected under this request as part of the “Business Master File (BMF)” and “Individual Master File (IMF) systems, and a Privacy Act System of Records notice (SORN) has been issued for these systems under Treasury/IRS 24.030 - Customer Account Data Engine (CADE) Individual Master File, Treasury/IRS 24.046 - CADE Business Master File (BMF), and Treasury/IRS 34.037 - Audit Trail and Security Records. The Internal Revenue Service PIAs can be found at https://www.irs.gov/privacy-disclosure/privacy-impact-assessments-pia.


Title 26 U.S.C. 6109 requires inclusion of identifying numbers in returns, statements, or other documents for securing proper identification of persons required to make such returns, statements, or documents and is the authority for social security numbers (SSNs) in IRS systems.


  1. ESTIMATED BURDEN OF INFORMATION COLLECTION

Chapters 11 and 13 of the IRC require decedent estates to provide information and keep records. The executor of the estate uses Form 706 to figure and report taxes imposed on the estate and certain GST taxes.









The burden estimate is as follows:


Description

# of Respondents

# Responses per Respondent

Annual Responses

Hours per Response

Total Burden Hours

Form 706

Form 706-A

Form 706-CE

Form 706 GS(D)

Form 706 GS(D-1)

Form 706-GS(T)

Form 706-NA

Form 706-QDT

25,037

1

25,037

10 hrs., 16 min.

254,424

Totals

25,037


25,037


254,424


The following regulations impose no additional burden. We are asking for continued approval of these regulations that are associated with Form 706. Please continue to assign OMB number 1545-0015 to these regulations.

7.639A-1

20.2032A-4

20.2106-2

20.6081-1

20.2010-2

20.2032A-8

20.2204-1

20.6091-1

20.2011-1

20.2039-4

20.2204-2

20.6161-1

20.2014-5

20.2051-1

20.6001-1

20.6161-2

20.2014-6

20.2053-3

20.6011-1

20.6163-1

20.2016-1

20.2053-9

20.6018-1

20.6166A-1

20.2031-2

20.2053-10

20.6018-2

20.6166A-3

20.2031-3

20.2055-1

20.6018-3

22.0

20.2031-4

20.2055-2

20.6018-4

25.2523(f)-1

20.2031-6

20.2055-3

20.6036-2

26.2662-1

20.2031-10

20.2056(b)-4

20.6061-1

301.6324A-1

20.2032-1

20.2056(b)-7

20.6065-1

301.7517-1

20.2032A-3

20.2106-1

20.6075-1



  1. ESTIMATED TOTAL ANNUAL COST BURDEN TO RESPONDENTS


IRS estimates the total annual cost to respondents at $8,473,082. 


To arrive at this figure, 51%a of burden of 254,424 was multiplied by $65.30 per hour. IRS anticipates that 51% of filers may use a tax professional to complete their Form 706 to report and compute the applicable tax.


The above Hourly Wage Rate is the May 2024 Bureau of Labor Statistics mean wage for “Accountant and Auditors” (Major Group (13-2011)” of $44.96 times the wage rate benefit multiplier of 1.4524 (to account for fringe benefits) equaling a fully-loaded wage rate of $65.30.


The benefits multiplier is estimated by dividing total compensation of $46.84 by salaries and wages of $32.25, based on Employer Cost for Employee Compensation, September 2024 data, released December 17, 2024.


  1. ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT


The federal government cost estimate is based on a model that considers the following three cost factors for each information product: aggregate labor costs for development, including annualized startup expenses, operating and maintenance expenses, and distribution of the product that collects the information. These costs do not include any activities such as taxpayer assistance and enforcement.


The government computes cost using a multi-step process. First, the government creates a weighted factor for the level of effort to create each information collection product based on variables, such as complexity, number of pages, type of product, and frequency of revision. Second, the total costs associated with developing the product such as labor cost, and operating expenses associated with the downstream impact such as support functions, are added together to obtain the aggregated total cost. Then, the aggregated total cost and factor are multiplied together to obtain the aggregated cost per product. Lastly, the aggregated cost per product is added to the cost of shipping and printing each product to IRS offices, National Distribution Center, libraries, and other outlets. The result is the government cost estimate per product.


The government cost estimate for this collection is summarized in the table below.

Product

Aggregate Cost per Product (factor applied)


Printing and Distribution


Government Cost Estimate

Form 706

$63,106

+

$0

=

$63,106

706 Instructions

$46,925

+

$1,702

=

$48,627

Form 706-A

$22,654

+

$0

=

$22,654

706-A Instructions

$4,854

+

$0

=

$4,854

Form 706-CE

$21,035

+

$0

=

$21,035

Form 706-GS(D)

$17,799

+

$0

=

$17,799

706-GS(D) Instructions

$4,854

+

$0

=

$4,854

Form 706-GS (D-1)

$21,035

+

$0

=

$21,035

706-GS(D-1) Instructions

$4,854

+

$0

=

$4,854

Form 706-GS(T)

$21,035

+

$0

=

$21,035

706-GS(T) Instructions

$6,472

+

$0

=

$6,472

Form 706-NA

$19,417

+

$0

=

$19,417

706-NA Instructions

$4,854

+

$0

=

$4,854

Form 706-QDT

$29,450

+

$0

=

$29,450

706-QDT Instructions

$7,362

+

$0

=

$7,362

Total

$295,706

+

$1,702

=

$297,408

Table costs are based on 2023 actuals obtained from IRS Chief Financial Officer and Media and Publications


  1. REASONS FOR CHANGE IN BURDEN


Changes in the layout of the forms along with updated burden estimates increase the annual responses by 10,770 and decrease the annual estimated burden by 262,666 hours.



Total Requested

Change Due to New Statute

Change Due to Agency Discretion

Change Due to Adjustment in Estimate

Change Due to Potential Violation of the PRA

Previously Approved

Annual Number of Responses


25,037


0


-200


10,970


0


14,267

Annual Time Burden (Hr.)


254,424


0


-268


-262,398


0


517,090


  1. PLANS FOR TABULATION, STATISTICAL ANALYSIS AND PUBLICATION


The intent of this collection is to collect data in areas of income, gains, losses, deductions, credits, and to figure the income tax liability of a taxpayer. There are no plans for the IRS to publish the information collected.


  1. REASONS WHY DISPLAYING THE OMB EXPIRATION DATE IS INAPPROPRIATE


The IRS believes that displaying the OMB expiration date is inappropriate because it could cause confusion by leading taxpayers to believe that the form or regulation expires as of the expiration date. Taxpayers are not likely to be aware that the IRS intends to request renewal of the OMB approval and obtain a new expiration date before the old one expires.


  1. EXCEPTIONS TO THE CERTIFICATION STATEMENT


There are no exceptions to the certification statement.


a IRS estimates, a 51% of taxpayers would seek a tax professional to complete their tax return based on IRS Data Book, 2023.

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