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

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Instructions for Form
706-GS(T)
(Rev. November 2025)

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

General Instructions

Future Developments

Purpose of Form

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 IRS.gov/
Form706GST.

Who Must File

What’s New
Part I—General Information. Entry lines in this section
were reorganized. Line 1b was modified to include TIN as
trust’s identification number.
Part II—Trust Information. Questions 3, 6, and 7 were
moved to Schedule A.
Part III—Tax Computation. Overpayment line now includes
option for direct deposit.
Part IV—Supplemental Trust Information. New part with
lines 11, 12, and 13 to provide additional information as
requested on Part II questions.
Schedule A. Schedule was reorganized to include previous
Schedule A, Schedule B(1), and Schedule B(2) into one
Schedule A with Parts I–V.
Electronic payments. The use of paper-based payments
(including checks and money orders) flowing into and out of
the federal government is being transitioned into electronic
payments to reduce delays, risks of fraud, lost payments,
theft, and inefficiencies. Go to IRS.gov/EO14247 for more
information.
Making a payment. Payments made to the federal
government must be processed electronically. See
Line 9—Tax Due and Non-electronic payment exceptions,
later, for information on how to make a payment.
Direct deposit. To the extent permitted by law, the
Secretary of the Treasury will cease issuing paper checks for
all federal disbursements. Direct deposit is now available for
this form. If there is an overpayment when filing your return,
complete Part II, lines 10b, 10c, and 10d to enter your direct
deposit information. See Line 10—Overpayment and
Non-electronic federal disbursement exceptions, later, for
more information.

Reminder
GST exemption increase. The generation-skipping transfer
(GST) tax exemption amount may increase yearly. See
Numerator. GST exemption, later.

May 20, 2025

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.
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 15 of
the year following the calendar year in which the 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.

Private Delivery Services (PDSs)

Filers can use certain PDSs designated by the IRS to meet
the “timely mailing as timely filing” rule for tax returns. 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.

!

CAUTION

PDSs can’t deliver items to P.O. boxes. You must use
the U.S. Postal Service to mail any item to an IRS
P.O. box address.

Where To File

File Form 706-GS(T) at the following address.
Department of the Treasury
Internal Revenue Service Center
Kansas City, MO 64999
If using a PDS, file at the following address.
Internal Revenue Service
333 W. Pershing Road
Kansas City, MO 64108

Instructions for Form 706-GS(T) (Rev. 11-2025) Catalog Number 10829R
Department of the Treasury Internal Revenue Service www.irs.gov

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Amending Form 706-GS(T)
The address for filing an amended Form 706-GS(T) is:
Internal Revenue Service Center
Stop 824G
7940 Kentucky Drive
Florence, KY 41042-2915
If using a PDS, file at the following address.
Internal Revenue Service Center
Stop 824G
7940 Kentucky Drive
Florence, KY 41042-2915

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:
• 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.
Taxable termination. 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:

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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

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• 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.

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.

Transition Rule in Case of Mental Disability

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.

Exceptions to Additions Rule

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.

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.
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
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.

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
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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

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.

Penalties and Interest

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.
Section 6662 provides penalties for underpayments of
GST taxes due to negligence, intentional disregard of rules
and regulations, or a substantial or gross valuation
understatement. 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. No penalty will be
assessed if the underpayment of GST tax, attributable to
substantial or gross valuation understatement, does not
exceed $5,000.
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.
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Return preparer. The Small Business and Work
Opportunity Act of 2007 extended return preparer penalties
to all return preparers. 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
derived (or to be derived) for the preparation of each such
return. Return preparers who prepare a 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 sections 6694(a) and 6694(b), the related regulations,
and Ann. 2009-15, 2009-11 I.R.B. 687 (available at
IRS.gov/pub/irs-irbs/irb09-11.pdf) for more information.

Signature

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.
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.
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); and Part III.

Part I—General Information
Line 1b. Trust’s Taxpayer Identification Number

All trusts filing Form 706-GS(T) must have a taxpayer
identification number (TIN). A nonexplicit trust, defined
above, must have a TIN that is separate from any other
entity’s TIN 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 a TIN should
apply for one. For additional information, go to IRS.gov/TIN.
Send the appropriate TIN form to the address listed under
Where To File. If you do not receive the TIN by the due date
for Form 706-GS(T), write “Applied for” on line 1b.

Part II—Trust Information
Line 3

Whenever property is transferred into a pre-existing trust, the
inclusion ratio must be refigured. If you answered “Yes,”
complete Part IV, line 11, stating how the inclusion ratio was
calculated. See Multiple transfers, later, for the rule on how to
refigure the inclusion ratio.

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Part III—Tax Computation

3. National security- or law enforcement-related activities
where non-EFT transactions are necessary or desirable.

Line 6b

4. Other circumstances as determined by the Secretary of
the Treasury, as reflected in regulations or other
guidance.

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 9—Tax Due

If the amount on line 7 is more than the amount on line 8,
subtract line 8 from line 7. This is the amount you owe.
Payments made to the federal government must be
processed electronically. Go to IRS.gov/EO14247 for more
information. Go to IRS.gov/Payments for more information on
how to make a payment and also see EFTPS and Same-day
wire below. If you qualify for an exception, an alternative
payment option (check or money order) may be permitted.
See Non-electronic payment exceptions, later, for more
information.
EFTPS. Payment of the tax due may be submitted
electronically through the Electronic Federal Tax Payment
System (EFTPS). EFTPS is a free service of the Department
of the Treasury.
To be considered timely, payments made through EFTPS
must be completed no later than 8 p.m. Eastern time the day
before the due date. All EFTPS payments must be scheduled
in advance of the due date and, if necessary, may be
changed or canceled up to 2 business days before the
scheduled payment date.
To get more information about EFTPS or to enroll in
EFTPS, go to EFTPS.gov or call 800-555-4477. To contact
EFTPS using Telecommunications Relay Service (TRS) for
people who are deaf, hard of hearing, or have a speech
disability, dial 711 and then provide the TRS assistant the
800-555-4477 number, above, or 800-733-4829. Additional
information about EFTPS is available in Pub. 966, Electronic
Federal Tax Payment System: A Guide to Getting Started.
Same-day wire. Payment of the tax due may be submitted
electronically through same-day wire from your financial
institution. Contact your financial institution for availability,
cost, and time frames.
What you need to know about making a same-day wire
payment.
• You do not need to enroll to make a same-day wire
payment, and no PIN is needed.
• Your financial institution may charge a fee for this service.
• The cutoff time to make a same-day wire payment is 5
p.m. Eastern time. Your financial institution may have an
earlier cutoff time.
• Download and complete page 1 of the Same-Day
Taxpayer Worksheet, and provide pages 1 and 2 to your
financial institution. See How do I make an electronic
payment? under Frequently asked questions on estate
taxes on IRS.gov for the worksheet and more information.
Non-electronic payment exceptions. If you qualify for one
of the exceptions below, a check or money order may still be
permitted as a payment option.
1. Individuals who do not have access to banking services
or electronic payment systems.
2. Certain emergency payments where electronic
disbursement would cause undue hardship, as
contemplated in 31 C.F.R. Part 208.

Note. If you don’t qualify for one of the exceptions above, an
electronic payment option must be used to make a payment.
If you do qualify for an exception above, go to IRS.gov/
Payments/Pay-by-Check-or-Money-Order for details on what
needs to go on the check to mail your payment.

Line 10—Overpayment

To the extent permitted by law, the Secretary of the Treasury
will cease issuing paper checks for all federal disbursements.
Direct deposit is available for this form. If there is an
overpayment when filing your return, complete Part III, lines
10b, 10c, and 10d to input your direct deposit information. If
you qualify for an exception, an alternative payment option
(paper check) may be permitted. See Non-electronic federal
disbursement exceptions, later, for more information.
Why use direct deposit? You get your refund faster

TIP by direct deposit than you do by check. Payment is

more secure. There is no check that can get lost or
stolen. It is more convenient. You don’t have to make a trip to
the bank to deposit your check. It saves tax dollars. It costs
the government less to refund by direct deposit. It’s proven
itself. Nearly 98% of social security and veterans’ benefits are
sent electronically using direct deposit.
Account must be in your name. Don’t request a deposit of
your refund to an account that isn’t in your name. The number
of refunds that can be directly deposited to a single account
or prepaid debit card is limited to three a year. After this limit
is reached, paper checks will be sent instead. Learn more at
IRS.gov/DepositLimit.

Line 10a

If the amount on line 8 is more than the amount on line 7,
subtract line 7 from line 8. This is the amount you overpaid. If
you want us to directly deposit the amount shown on line 10a
to your checking or savings account at a U.S. bank or other
U.S. financial institution (such as a mutual fund, brokerage
firm, or credit union) complete lines 10b through 10d.

Line 10b

The routing number for your financial institution must be nine
digits. The first two digits must be 01 through 12 or 21
through 32. Otherwise, the direct deposit will be rejected and
a check sent instead.

Line 10c

Check the appropriate box for the type of account. Don’t
check more than one box. You must check the correct box to
ensure your deposit is accepted.

Line 10d

The account number can be up to 17 characters (both
numbers and letters). Include hyphens but omit spaces and
special symbols. Enter the number from left to right and leave
any unused boxes blank. Don’t include the check number.
If the direct deposit to your account is different from the
amount you expected, you will receive an explanation in the
mail about 2 weeks after your refund is deposited.
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Reasons your direct deposit will be rejected. If any of
the following apply, your direct deposit request will be
rejected and a check will be sent instead.
• You are asking to have a joint refund deposited to an
individual account, and your financial institution(s) won’t
allow this. The IRS isn’t responsible if a financial
institution rejects a direct deposit.
• The name on your account doesn’t match the name on
the refund, and your financial institution(s) won’t allow a
refund to be deposited unless the name on the refund
matches the name on the account.
• Three direct deposits of tax refunds have already been
made to the same account or prepaid debit card.
• You haven’t given a valid account number.
• Any numbers or letters on lines 10b through 10d are
crossed out or whited out.

Schedule A

The IRS isn’t responsible for a lost refund if you enter
the wrong account information. Check with your
CAUTION financial institution to get the correct routing and
account numbers and to make sure your direct deposit will be
accepted.

Line 3

!

Non-electronic federal disbursement exceptions. If you
qualify for one of the exceptions below, a paper check may
still be permitted as a federal disbursement option.
1. Individuals who do not have access to banking services
or electronic payment systems.
2. Certain emergency payments where electronic
disbursement would cause undue hardship, as
contemplated in 31 C.F.R. Part 208.
3. National security- or law enforcement-related activities
where non-EFT transactions are necessary or desirable.
4. Other circumstances as determined by the Secretary of
the Treasury, as reflected in regulations or other
guidance.
Note. If you don’t qualify for one of the exceptions above, the
direct deposit information must be entered on lines 10b, 10c,
and 10d. If you do qualify for an exception above, leave lines
10b, 10c, and 10d blank.

Part IV—Supplemental Trust
Information
Line 11

Whenever property is transferred into a pre-existing trust, the
inclusion ratio must be refigured. If you answered “Yes” on
Part II, line 3, show how the inclusion ratio was calculated.

Line 12

Describe terminations that occurred and are not reported on
this return because of the exceptions in section 2611(b)(1) or
(2) relating to medical and educational exclusions and prior
payment of generation-skipping transfer (GST) tax. Complete
if you answered “Yes” on Part II, line 4.

Line 13

Describe the trust arrangement that makes its effect
substantially similar to an explicit trust. Complete if answered
“Yes” on Part II, line 5.

Note. If you need more than one Schedule A, make copies
before completing it. If you need more space than is provided
for Parts I, II, and III, duplicate and use if additional entries
are needed. Make sure that the total amounts from the
additional Schedule(s) A are included on the corresponding
line for each part.
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.

Part I—Taxable Termination
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.

Line 5

For the purposes of line 5, 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 6

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 6 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.

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1. Any property distributed or otherwise disposed of or
separated from 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 7
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, “0.00123”).
Column (a). Item number. 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, 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 so that the IRS can value it.
Column (d). Valuation date. Unless you elected alternate
valuation by checking the box on line 6 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.

Part II—General Trust Debts, Expenses, and
Taxes (Section 2622(b))

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.
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 number. 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.
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Line 15

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 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.

Part III—Specific Termination-Related Debts,
Expenses, and Taxes (Section 2622(b))

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.
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 number. 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.

Part IV—Schedule A GST Tax Calculation
Line 25. 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.

8

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, “0.001”).
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 thereafter 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 . . . . . . . . . . .
2015 . . . . . . . . . . .
2016 . . . . . . . . . . .
2017 . . . . . . . . . . .
2018 . . . . . . . . . . .
2019 . . . . . . . . . . .
2020 . . . . . . . . . . .
2021 . . . . . . . . . . .
2022 . . . . . . . . . . .
2023 . . . . . . . . . . .
2024 . . . . . . . . . . .
2025 . . . . . . . . . . .

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

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
$5,430,000
$5,450,000
$5,490,000
$11,180,000
$11,400,000
$11,580,000
$11,700,000
$12,060,000
$12,920,000
$13,610,000
$13,990,000

See Rev. Proc. 2024-40, 2024-45 I.R.B. 1100, available at
Rev. Proc. 2024-40, as modified and supplemented by
subsequent revenue procedures, for the GST exemption
amount on subsequent years.
A valid Deceased Spousal Unused Exclusion
Amount ("DSUE" or portability) election by an
CAUTION executor of a deceased spouse’s estate does not
apply to or impact GST tax exemption.

!

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.

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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).
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 26

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

The maximum
tax rate is

After December 31, 2002, but before January
1, 2004 . . . . . . . . . . . . . . . . . . . . . . . .

49%

After December 31, 2003, but before January
1, 2005 . . . . . . . . . . . . . . . . . . . . . . . .

48%

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

47%

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

46%

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

45%

After December 31, 2009, but before January
1, 2011 . . . . . . . . . . . . . . . . . . . . . . . .

0%

After December 31, 2010, but before January
1, 2013 . . . . . . . . . . . . . . . . . . . . . . . .

35%

After December 31, 2012

40%

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

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Part V—Supplemental Information
Line 29

For all circumstances, describe how the trust’s inclusion ratio
was determined in accordance with the allocation rules of
section 2632.

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