Succession: Russia → United States

Inheritance received from an individual is generally exempt from Russian personal income tax under Tax Code Article 217. The FNS separately identifies remuneration paid to heirs of authors of scientific, literary and artistic works and inventions as taxable income. From 2026, foreign-agent recipients lose the inheritance-income exemption. Notarial costs and other-structure consequences require separate review.

This is general source context. Estate assets, death date, decedent and heir status, kinship, reliefs, treaties and local rules require review; no personal tax is calculated here.

• C6 tax context ru_foreign_agent_2026 — Все ФЛ ИП ЮЛ Фильтр по категории налогоплательщиков НДФЛ ФЛ ИП ЮЛ По доходам иностранных агентов, полученным с 2026 года, НК РФ устанавливается новая система обложения НДФЛ: к их доходам (в том числе от продажи имущества) будет применяться ставка 30 %; доходы от продажи ценных бумаг, имущества (при владении более пяти лет), при получении наследства и в порядке дарения с 2026 года лишаются освобождения от обложения НДФЛ; таким лицам не будут предоставляться налоговые вычеты по НДФЛ. Также доходы иностранных агентов (если в течение хотя бы одного дня налогового периода, в котором получен соответствующий доход, есть указанный статус), полученные в виде подарка от физического лица, с 2026 года облагаются НДФЛ вне зависимости от степени родства с дарителем по ставке 30%. — addressed_visible_projection:при получении наследства — Checked: 2026-10-18
• C6 tax context ru_general — В соответствии со ст.217 НК РФ не все доходы физических лиц облагаются НДФЛ Доходы, облагаемые НДФЛ Доходы, не облагаемые НДФЛ от продажи имущества, находившегося в собственности менее трех (пяти) лет; от сдачи имущества в аренду; доходы от источников за пределами Российской Федерации; доходы в виде разного рода выигрышей; иные доходы. доходы от продажи имущества, находившегося в собственности более трех (пяти) лет; доходы, полученные в порядке наследования; доходы, полученные по договору дарения от члена семьи и (или) близкого родственника в соответствии с Семейным кодексом Российской Федерации (от супруга, родителей и детей, в том числе усыновителей и усыновленных, дедушки, бабушки и внуков, полнородных и неполнородных (имеющих общих отца или мать) братьев и сестер); иные доходы. Отчетный период Год Налоговый период Год Порядок уплаты НДФЛ в виде фиксированного авансового платежа распространен на иностранных граждан, прибывших в Российскую Федерацию в безвизовом режиме и работающих на основании патента не только у физических лиц (как было до 2015 года), но и в организациях,у индивидуальных предпринимателей или занимающихся частной практикой лиц (например, адвокатов, учредивших адвокатский кабинет). — addressed_visible_projection:доходы, полученные в порядке наследования — Checked: 2026-10-18
• C6 tax context ru_general — физические лица, получающие доходы в виде вознаграждения, выплачиваемого им как наследникам авторов произведений науки, литературы, искусства, а также авторов изобретений; — FNS general NDFL: authors’ heirs remuneration, complete list item — Checked: 2026-10-18

The retained full EPTL5-1.1-A gives a qualifying surviving spouse a personal election, subject to death-date conditions and net-estate, testamentary-substitute and credit rules. The greater-of50000dollars(or the smaller netestate) and one-third formula is not a general heir allowance or unconditional payment. The full section contains limits, procedural election, deadlines and waiver; applicability, death, domicile, assets and renunciation need separate review. This example defeats an unrestricted-testamentary-freedom claim for allU.S. states, but establishes no other state’s law.

where (part of the country): New York (state)

This records the named sources; it does not determine personal entitlement, the exhaustive currently governing rule or applicability to a particular case. Territory, dates, documents, party facts and exceptions require separate assessment. England and Wales under the1975Act and separately NewYork under EPTL; not allUK/USA or an automatic share for every relative.

• New York EPTL 5-1.1-A — §5-1.1-A complete addressed web-tool lines52-371 — § 5-1.1-A Right of election by surviving spouse (a) Where a decedent dies on or after September first, nineteen hundred ninety-two and is survived by a spouse, a personal right of election is given to the surviving spouse to take a share of the decedent's estate, subject to the following: (1) For the purpose of this section, the decedent's estate includes the capital value, as of the decedent's death, of any property described in subparagraph (b) (1). (2) The elective share, as used in this paragraph, is the pecuniary amount equal to the greater of (i) fifty thousand dollars or, if the capital value of the net estate is less than fifty thousand dollars, such capital value, or (ii) one third of the net estate. In computing the net estate, debts, administration expenses and reasonable funeral expenses shall be deducted, but all estate taxes shall be disregarded, except that nothing contained herein relieves the surviving spouse from contributing to all such taxes the amounts apportioned against him or her under 2-1.8. (3) The term "testamentary provision", as used in this paragraph, includes, in addition to dispositions made by the decedent's will, distributions of property pursuant to 4-1.1 and any transaction described as a testamentary substitute in subparagraph (b) (1). (4) The share of the testamentary provisions to which the surviving spouse is entitled hereunder (the "net elective share") is his or her elective share, as defined in subparagraphs (1) and (2), reduced by the capital value of any interest which passes absolutely from the decedent to such spouse, or which would have passed absolutely from the decedent to such spouse but was renounced by the spouse, (i) by intestacy, (ii) by testamentary substitute as described in subparagraph (b) (1), or (iii) by disposition under the decedent's last will. (A) Unless the decedent has provided otherwise, if a spouse elects under this section, such election shall have the same effect with respect to any interest which passes or would have passed to the spouse, other than absolutely, as though the spouse died on the same date but immediately before the death of the decedent. (B) For the purposes of this subparagraph (4), (i) an interest in property shall be deemed to pass other than absolutely from the decedent to the spouse if the interest so passing consists of less than the decedent's entire interest in that property or consists of any interest in a trust or trust equivalent created by the decedent; and (ii) an interest in property shall be deemed to pass absolutely from the decedent to the spouse if it is not deemed to pass other than absolutely. (5) Where a decedent dies before September first, nineteen hundred ninety-four, paragraphs (c)(1)(D) through (c)(1)(K) of section 5-1.1 shall apply except that the words "fifty thousand dollars" shall be substituted for the words "ten thousand dollars" wherever they appear in such paragraphs. (b) Inter vivos dispositions treated as testamentary substitutes for the purpose of election by surviving spouse. (1) Where a person dies after August thirty-first, nineteen hundred ninety-two and is survived by a spouse who exercises a right of election under paragraph (a), the transactions affected by and property interests of the decedent described in clauses (A) through (H), whether benefiting the surviving spouse or any other person, shall be treated as testamentary substitutes and the capital value thereof, as of the decedent's death, shall be included in the net estate subject to the surviving spouse's elective right except to the extent that the surviving spouse has executed a waiver of release pursuant to paragraph (e) with respect thereto. Notwithstanding the foregoing, a transaction, other than a transaction described in clause (G), that is irrevocable or is revocable only with the consent of a person having a substantial adverse interest (including any such transactions with respect to which the decedent retained a special power of appointment as defined in 10-3.2), will constitute a testamentary substitute only if it is effected after the date of the marriage. (A) Gifts causa mortis. (B) The aggregate transfers of property (including the transfer, release or relinquishment of any property interest which, but for such transfer, release or relinquishment, would come within the scope of clause (F)), other than gifts causa mortis and transfers coming within the scope of clauses (G) and (H), to or for the benefit of any person, made after August thirty-first, nineteen hundred ninety-two, and within one year of the death of the decedent, to the extent that the decedent did not receive adequate and full consideration in money or money's worth for such transfers; provided, however, that any portion of any such transfer that was excludible from taxable gifts pursuant to subsections (b) and (e) of section two thousand five hundred three of the United States Internal Revenue Code, including any amounts excluded as a result of the election by the surviving spouse to treat any such transfer as having been made one half by him or her, shall not be treated as a testamentary substitute. (C) Money deposited, together with all dividends or interest credited thereon, in a savings account in the name of the decedent in trust for another person, with a banking organization, savings and loan association, foreign banking corporation or organization or bank or savings and loan association organized under the laws of the United States, and remaining on deposit at the date of the decedent's death. (D) Money deposited after August thirty-first, nineteen hundred sixty-six, together with all dividends or interest credited thereon, in the name of the decedent and another person and payable on death, pursuant to the terms of the deposit or by operation of law, to the survivor, with a banking organization, savings and loan association, foreign banking corporation or organization or bank or savings and loan association organized under the laws of the United States, and remaining on deposit at the date of the decedent's death. (E) Any disposition of property made by the decedent whereby property, at the date of his or her death, is held (i) by the decedent and another person as joint tenants with a right of survivorship or as tenants by the entirety where the disposition was made after August thirty-first, nineteen hundred sixty-six, or (ii) by the decedent and is payable on his or her death to a person other than the decedent or his or her estate. (F) Any disposition of property or contractual arrangement made by the decedent, in trust or otherwise, to the extent that the decedent (i) after August thirty-first, nineteen hundred ninety-two, retained for his or her life or for any period not ascertainable without reference to his or her death or for any period which does not in fact end before his or her death the possession or enjoyment of, or the right to income from, the property except to the extent that such disposition or contractual arrangement was for an adequate consideration in money or money's worth; or (ii) at the date of his or her death retained either alone or in conjunction with any other person who does not have a substantial adverse interest, by the express provisions of the disposing instrument, a power to revoke such disposition or a power to consume, invade or dispose of the principal thereof. The provisions of this subparagraph shall not affect the right of any income beneficiary to the income undistributed or accrued at the date of death nor shall they impair or defeat any right which has vested on or before August thirty-first, nineteen hundred ninety-two. (G) Any money, securities or other property payable under a thrift, savings, retirement, pension, deferred compensation, death benefit, stock bonus or profit-sharing plan, account, arrangement, system or trust, except that with respect to a plan to which subsection (a) (11) of section four hundred one of the United States Internal Revenue Code applies or a defined contribution plan to which such subsection does not apply pursuant to paragraph (B) (iii) thereof, only to the extent of fifty percent of the capital value thereof. Notwithstanding the foregoing, a transaction described herein shall not constitute a testamentary substitute if the decedent designated the beneficiary or beneficiaries of the plan benefits on or before September first, nineteen hundred ninety-two and did not change such beneficiary designation thereafter. (H) Any interest in property to the extent the passing of the principal thereof to or for the benefit of any person was subject to a presently exercisable general power of appointment, as defined in section two thousand forty-one of the United States Internal Revenue Code, held by the decedent immediately before his or her death or which the decedent, within one year of his or her death, released (except to the extent such release results from a lapse of the power which is not treated as a release pursuant to section two thousand forty-one of the United States Internal Revenue Code) or exercised in favor of any person other than himself or herself or his or her estate. (I) A transfer of a security to a beneficiary pursuant to part 4 of article 13 of this chapter. (2) Transactions described in clause (D) or (E) (i) shall be treated as testamentary substitutes in the proportion that the funds on deposit were the property of the decedent immediately before the deposit or the consideration for the property described in clause (E) (i) was furnished by the decedent. The surviving spouse shall have the burden of establishing the proportion of the decedent's contribution; provided, however, that where the surviving spouse is the other party to the transaction, it will be conclusively presumed that the proportion of the decedent's contribution is one-half. For the purpose of this subparagraph, the court may accept such evidence as is relevant and competent, whether or not the person offering such evidence would otherwise be competent to testify. (3) The property referred to in clause (E) shall include United States savings bonds and other United States obligations. (4) The provisions of this paragraph shall not prevent a corporation or other person from paying or transferring any funds or property to a person otherwise entitled thereto, unless there has been served personally upon such corporation or other person a certified copy of an order enjoining such payment or transfer made by the surrogate's court having jurisdiction of the decedent's estate or by another court of competent jurisdiction. A corporation or other person paying or transferring any funds or property described in clause (G) of subparagraph one of this paragraph to a person otherwise entitled thereto, shall be held harmless and free from any liability for making such payment or transfer, in any action or proceeding which involves such funds or property. Such order may be made, on notice to such persons and in such manner as the court may direct, upon application of the surviving spouse or any other interested party and on proof that the surviving spouse has exercised his or her right of election under paragraph (a). Service of a certified copy of such order on the corporation or other person holding such fund or property shall be a defense, during the effective period of the order, in any action or proceeding which involves such fund or property. (5) This paragraph shall not impair or defeat the rights of creditors of the decedent with respect to any matter as to which any such creditor has rights. (6) In case of a conflict between this paragraph and any other provision of law affecting the transactions described in subparagraph (1) of this paragraph, this paragraph controls. (7) If any part of this section is preempted by federal law with respect to a payment or an item of property included in the net estate, a person who, not for value, received that payment or item of property is obligated to return to the surviving spouse that payment or item of property or is personally liable to the surviving spouse for the amount of that payment or the value of that item of property, to the extent required under this section. (c) General provisions governing right of election. (1) Where an election has been made under this section, the will or other instrument making a testamentary provision, as the case may be, is valid as to the residue after the share to which the surviving spouse is entitled has been deducted, and the terms of such will or instrument remain otherwise effective so far as possible, subject, however, to the provisions of clause (a)(4)(A). (2) Except as otherwise expressly provided in the will or other instrument making a testamentary provision, ratable contribution to the share to which the surviving spouse is entitled shall be made by the beneficiaries and distributees (including the recipients of any such testamentary provision), other than the surviving spouse, under the decedent's will, by intestacy and other instruments making testamentary provisions, which contribution may be made in cash or in the specific property received from the decedent by the person required to make such contribution or partly in cash and partly in such property as such person in his or her discretion shall determine. (3) The right of election is personal to the surviving spouse, except that an election may be made by: (A) The guardian of the property of an infant spouse, when so authorized by the court having jurisdiction of the decedent's estate. (B) The committee of an incompetent spouse, when so authorized by the court that appointed the committee. (C) The conservator of a conservatee spouse, when so authorized by the court that appointed the conservator. (D) The guardian ad litem for the surviving spouse when so authorized by the court that appointed such guardian. (E) A guardian authorized under Article 81 of the mental hygiene law, when so authorized by the court that appointed the guardian. (4) Any question arising as to the right of election shall be determined by the court having jurisdiction of the decedent's estate in a proceeding brought for that purpose on notice to all interested persons in such manner as the court may direct, or in a proceeding for the judicial settlement of the accounts of the personal representative. (5) Upon application by a surviving spouse who has made an election under this section, the court may make an order cancelling such election, provided that no adverse rights have intervened and no prejudice is shown to creditors of such spouse or other persons interested in the estate. Such application shall be made on notice to such persons and in such manner as the court may direct. A certified copy of such order shall be indexed and recorded in the same manner as a notice of pendency of an action in the office of the clerk of the county in which any real property of the decedent is situated. (6) The right of election granted by this section is not available to the spouse of a decedent who was not domiciled in this state at the time of death, unless such decedent has elected, under paragraph (h) of 3-5.1, to have the disposition of his or her property situated in this state governed by the laws of this state. (7) The decedent's estate shall include all property of the decedent wherever situated. (8) An election made by the surviving spouse under this section is in lieu of any right of dower to which such spouse may be entitled. (9) The references in this paragraph to sections of the United States Internal Revenue Code are to the Internal Revenue Code of 1986, as amended. Such references, however, shall be deemed to constitute references to any corresponding provisions of any subsequent federal tax code. (d) Procedure for exercise of right of election. (1) An election under this section must be made within six months from the date of issuance of letters testamentary or of administration, as the case may be, but in no event later than two years after the date of decedent's death, except as otherwise provided in subparagraph 2 of this paragraph. Written notice of such election shall be served upon any personal representative in the manner herein provided, or upon a person named as executor in a will on file in the surrogate's court in a case where such will has not yet been admitted to probate, and the original thereof shall be filed and recorded, with proof of service, in the surrogate's court in which such letters were issued within six months from the date of the issuance of letters but in no event later than two years from the date of decedent's death, except as otherwise provided in subparagraph 2 of this paragraph. Such notice may be served by mailing a copy thereof, addressed to any personal representative, or to the nominated executor, as the case may be, at the place of residence stated in the designation required by section 708 of the surrogate's court procedure act, to the domicile address of such nominated executor, or in such other manner as the surrogate may direct. (2) The time to make such election may be extended before expiration by an order of the surrogate's court from which such letters issued for a further period not exceeding six months upon any one application. If the spouse defaults in filing such election within the time provided in subparagraph (1) of this paragraph, the surrogate's court may relieve the spouse from such default and authorize the making of an election within the period fixed by the order, provided that no decree settling the account of the personal representative has been made and that twelve months have not elapsed since the issuance of the letters, and two years have not elapsed since the decedent's date of death, in the case of initial application; except that the court may, in its discretion for good cause shown, extend the time to make such election beyond such period of two years. An application for relief from the default and for an extension of time to elect shall be made upon a petition showing reasonable cause and on notice to such persons and in such manner as the surrogate may direct. A certified copy of such order shall be indexed and recorded in the same manner as a notice of pendency of an action in the office of the clerk of each county in which real property of the decedent is situated. (3) The time limited in this paragraph for making an election is exclusive and shall not be suspended or otherwise affected by any provision of law, except that the surrogate may, in his or her discretion, permit an election to be made in behalf of an infant or incompetent spouse at any time up to, but no later than, the entry of the decree of the first judicial account of the representative of the estate, made more than seven months after the issuance of letters. (e) Waiver or release of right of election. (1) A spouse, during the lifetime of the other, may waive or release a right of election, granted by this section, against a particular or any last will or a testamentary substitute, as described in subparagraph (b) (1) made by the other spouse. A waiver or release of all rights in the estate of the other spouse is a waiver or release of a right of election against any such last will or testamentary provision. (2) To be effective under this section, a waiver or release must be in writing and subscribed by the maker thereof, and acknowledged or proved in the manner required by the laws of this state for the recording of a conveyance of real property. (3) Such a waiver or release is effective, in accordance with its terms, whether: (A) Executed before or after the marriage of the spouses. (B) Executed before, on or after September first, nineteen hundred sixty-six. (C) Unilateral in form, executed only by the maker thereof, or bilateral in form, executed by both spouses. (D) Executed with or without consideration. (E) Absolute or conditional. (4) If there is in effect at the time of the decedent's death a waiver, or a consent to the decedent's waiver, executed by the surviving spouse with respect to any survivor benefit, or right to such benefit, under subsection (a) (11) of section four hundred one or section four hundred seventeen of the United States Internal Revenue Code, then such waiver shall be deemed to be a waiver within the meaning of this paragraph (e) against the testamentary substitute constituting such benefit. — §5-1.1-A complete addressed web-tool lines52-371 — Source date: 2018-08-31 — Checked: 2026-10-18

US federal estate tax uses a progressive schedule with a top 40% marginal rate above $1 million of the relevant tax-computation amount. For a decedent who at death was neither US domiciled nor a US citizen for estate-tax purposes, the executor must file Form 706-NA if death-date US-situs assets, the specified gift-tax exemption for gifts made from 9 September through 31 December 1976, and adjusted taxable gifts after 31 December 1976 together exceed $60,000. The ordinary maximum unified credit of $13,000 corresponds to tax on the first $60,000 under the base schedule; treaties, US-territory and expatriation rules and other conditions can change the calculation. Stock issued by a US-law corporation is generally US situs. These are decedent-estate rules, not a personal allowance for a foreign heir.

This is general source context. Estate assets, death date, decedent and heir status, kinship, reliefs, treaties and local rules require review; no personal tax is calculated here.

• C6 tax context us_nrnc — To the taxable estate, add the value of lifetime taxable gifts, beginning with gifts made in 1977, of tangible or intangible property located in the United States that was transferred directly or indirectly, and not included in the gross estate. If the date of death value of the decedent’s U.S.-situated assets, together with the gift tax specific exemption and the amount of the adjusted taxable gifts, exceeds the filing threshold of $60,000, the executor must file a Form 706-NA for the decedent’s estate. The filing threshold for Form 706-NA is not indexed for inflation. See the Instructions for Form 706-NA for additional information on the gift tax specific exemption and the amount of adjusted taxable gifts. The Form 706-NA, United States Estate (and Generation-Skipping Transfer) Tax Return Estate of nonresident not a citizen of the United States , if required, must be filed within 9 months after the date of death unless an extension of time to file was granted. — addressed_visible_projection:filing threshold of $60,000 — Checked: 2026-10-18
• C6 tax context us_situs — For estate tax purposes, a citizen of a U.S. possession is not a U.S. citizen. U.S.-situated assets that are subject to estate tax include, for example: Real estate located in the U.S., Tangible personal property (excluding some art), and Stock of corporations organized in or under U.S. law, even if the nonresident held the certificates abroad or registered the certificates in the name of a nominee. Examples of property treated as situated outside the U.S., and therefore not subject to the U.S. estate tax, include certain deposits and debt obligations described in Section 871(g)-(i), bank accounts deposited with a foreign branch of a domestic commercial banking business, and proceeds of life insurance on the life of a nonresident who is not a U.S. citizen. — IRS US-situs examples and complete concluding excluded-property sentence — Checked: 2026-10-18
• C6 tax context us_instr_na — Department of the Treasury Internal Revenue Service Center Kansas City, MO 64999 Part II—Tax Computation Lines 4 and 5 To determine the tentative tax on the amount on line 2 (to be entered on line 5) and the tentative tax on the amount on line 3 (to be entered on line 4), use Table A—Unified Rate Schedule in the version of the Instructions for Form 706 that corresponds to the decedent's date of death. Line 7 Enter the unified credit. The unified credit is allowed for the smaller of the line 6 amount or the maximum unified credit. In general, the maximum unified credit is $13,000. For a citizen of a U.S. territory (see section 2209), the maximum unified credit is the greater of: $13,000, or The product of $46,800 times a fraction. The numerator of the fraction is the part of the gross estate located in the United States (line 1 of Part IV), and the denominator is the entire gross estate wherever located (line 3 of Part IV). If the unified credit is affected by a treaty, see section 2102(b)(3)(A). — addressed_visible_projection:maximum unified credit is $13,000 — Checked: 2026-10-18
• C6 tax context us_instr_na — Who Must File The executor must file Form 706-NA if the date of death value of the decedent’s U.S.-situated assets, together with the gift tax specific exemption and the amount of adjusted taxable gifts, exceeds the filing threshold of $60,000. The gift tax specific exemption refers to the amount allowed for gifts made by the decedent between September 9, 1976, and December 31, 1976, inclusive. The amount of adjusted taxable gifts refers to the amount of adjusted taxable gifts made by the decedent after December 31, 1976. — Form706-NA complete filing formula and historic gift definitions — Checked: 2026-10-18
• C6 tax context us_instr_na — Definitions The following definitions apply in these instructions. United States. The United States means the 50 states and the District of Columbia. Domicile. For estate tax purposes, a person acquires domicile in a place by living there, for even a brief period of time, with no definite present intention of later moving. See Regulations section 20.0-1 for more information. Nonresident not a citizen of the United States (NRNC). For estate tax purposes, a decedent is a nonresident not a citizen of the United States (NRNC) if the decedent is neither domiciled in nor a citizen of the United States at the time of death. A decedent who acquired U.S. citizenship solely by reason of being a citizen of a U.S. territory or by reason of birth or residence within a U.S. territory is not treated as a U.S. citizen. Note. A decedent may be a U.S. resident for income tax purposes yet be considered a nonresident for estate tax purposes. Long-term U.S. resident. A long-term U.S. resident is an individual (other than a U.S. citizen) who has been a lawful permanent resident of the United States (green card holder) for income tax purposes in at least 8 of the last 15 tax years ending with the tax year in which U.S. income tax residency is terminated. For more information, see section 877(e). For information regarding the definition of lawful permanent resident, including circumstances in which the lawful permanent resident status of a treaty resident is considered terminated, see the Instructions for Form 8854, Initial and Annual Expatriation Statement. Executor. An executor is the personal representative, executor, executrix, administrator, or administratrix of the decedent’s estate. If no executor is appointed, qualified, and acting in the United States, every person in actual or constructive possession of any of the decedent's property is considered an executor and must file a return. If more than one person must file, it is preferable that they join in filing one complete return. Otherwise, each person must file as complete a return as possible, including a full description of the property and each person's name who holds an interest in it. Executors must provide documentation proving their status. Documentation will vary but may include a certified copy of the will or a court order designating the executor(s). A statement by the executor(s) attesting to their status is insufficient. Expatriate. A decedent is an expatriate if the decedent relinquished U.S. citizenship or terminated long-term residency. Special estate tax rules may apply to decedents who expatriated from the United States prior to death. See Taxation Applicable to Certain Expatriates , next. Taxation Applicable to Certain Expatriates Expatriation on or after June 17, 2008. Decedent’s who expatriated on or after June 17, 2008, generally are subject to U.S. estate tax in the same manner as all other NRNC decedents. Note. For decedents who expatriated on or after June 17, 2008, and were “covered expatriates” as defined in section 877A(g)(1), any bequests or other transfers from the covered expatriate decedent’s estate to a U.S. citizen or resident beneficiary may subject the U.S. citizen or resident beneficiary to the section 2801 tax on the receipt of the gift or bequest. For more information on the section 2801 tax, see section 2801. To avoid the potential for subjecting property to both estate tax (payable by the executor of the covered expatriate decedent's estate) and section 2801 tax (payable by the U.S. citizen or resident receiving the property), any required Form 706-NA should be timely filed. See section 2801(e)(2)(B) and Regulations section 28.2801-3(c)(2) for details. Expatriation after June 3, 2004, and before June 17, 2008. Special estate tax rules under section 2107 apply to determine the value of the decedent’s U.S. taxable estate if the decedent was subject to the 10-year alternative tax regime of section 877(b) on the date of death. See the instructions for Line 6a and Line 6b , later. A decedent is subject to the 10-year alternative tax regime of section 877(b) (and thus is subject to section 2107), if the decedent expatriated after June 3, 2004, and before June 17, 2008, and also met one of three tests set out under section 877(a). The decedent’s average annual net income tax liability for the 5 tax years ending before the date of expatriation is: $124,000 for decedents who expatriated in 2004, $127,000 for decedents who expatriated in 2005, $131,000 for decedents who expatriated in 2006, $136,000 for decedents who expatriated in 2007, and $139,000 for decedents who expatriated in 2008. The decedent’s net worth was $2 million or more on the date of expatriation. The decedent’s failure to certify on Form 8854 that the decedent complied with all federal tax obligations for the 5 tax years preceding the date of expatriation. The 10-year alternative tax regime of section 877(b) commences when Form 8854 is filed. See section 877, 2107, and 7701(n) as in effect before June 17, 2008, and Form 8854 for additional information regarding the 10-year alternative tax regime. — Form706-NA definitions and special expatriation rules, including distinction from income-tax residence — Checked: 2026-10-18
• C6 tax context us_instr_706 — Table A—Unified Rate Schedule Column A Taxable amount over Column B Taxable amount not over Column C Tax on amount in column A Column D Rate of tax on excess over amount in column A $0 $10,000 $0 18% 10,000 20,000 1,800 20% 20,000 40,000 3,800 22% 40,000 60,000 8,200 24% 60,000 80,000 13,000 26% 80,000 100,000 18,200 28% 100,000 150,000 23,800 30% 150,000 250,000 38,800 32% 250,000 500,000 70,800 34% 500,000 750,000 155,800 37% 750,000 1,000,000 248,300 39% 1,000,000 – – – – 345,800 40% Line 1 If you elected alternate valuation on Part III, line 1, enter the amount you entered in the “Alternate value” column of Part V, item 13. Otherwise, enter the amount from the “Value at date of death” column. Line 3b. State Death Tax Deduction You may take a deduction on line 3b for estate, inheritance, legacy, or succession taxes paid on any property included in the gross estate as the result of the decedent’s death to any state or the District of Columbia. — addressed_visible_projection:1,000,000 – – – – 345,800 40% — Checked: 2026-10-18

estate tax

• Instructions for Form706 (RevJuly2026) — The executor of a decedent’s estate uses Form 706 to figure the estate tax imposed by chapter 11 of the Internal Revenue Code. This tax is levied on the entire taxable estate and not just on the share received by a particular beneficiary. — Purpose of Form — Checked: 2026-10-07

estate tax

• Instructions for Form706 (RevJuly2026) — The executor of a decedent’s estate uses Form 706 to figure the estate tax imposed by chapter 11 of the Internal Revenue Code. This tax is levied on the entire taxable estate and not just on the share received by a particular beneficiary. — Purpose of Form — Checked: 2026-10-07

US citizenship or US domicile at death — worldwide

who: citizen (national)

• Instructions for Form706 (RevJuly2026) — File Form 706 for the estates of decedents who were either U.S. citizens or U.S. residents at the time of death. For estate tax purposes, a resident is someone who had a domicile in the United States at the time of death. — Citizens/residents/domicile — Checked: 2026-10-07
• Instructions for Form706 (RevJuly2026) — The gross estate includes all property in which the decedent had an interest (including property outside the United States). — Gross Estate — Checked: 2026-10-07

US citizenship or US domicile at death — worldwide

who: domiciled in the country

• Instructions for Form706 (RevJuly2026) — File Form 706 for the estates of decedents who were either U.S. citizens or U.S. residents at the time of death. For estate tax purposes, a resident is someone who had a domicile in the United States at the time of death. — Citizens/residents/domicile — Checked: 2026-10-07
• Instructions for Form706 (RevJuly2026) — The gross estate includes all property in which the decedent had an interest (including property outside the United States). — Gross Estate — Checked: 2026-10-07

not a party

• HCCH Convention status table and declarations — Contracting Party S 1 R/A/S 2 Type 3 EIF 4 EXT 5 Auth 6 Res/D/N/DC 7 Albania 25-X-2013 A 24-XII-2013 Res 10,12 Antigua and Barbuda 1-V-1985 Su 1-XI-1981 Armenia 1-III-2007 A 30-IV-2007 Res 10,12,13 Australia 22-IX-1986 A 21-XI-1986 D 17 Austria 5-X-1961 28-X-1963 R 5-I-1964 Res 12 Belgium 10-X-1968 20-X-1971 R 19-XII-1971 Res 10 Bosnia and Herzegovina 23-VIII-1993 Su 6-III-1992 Botswana 18-XI-1968 A 17-I-1969 Res 1,8 Brunei Darussalam 10-V-1988 A 9-VII-1988 China (the People's Republic of) C N Croatia 23-IV-1993 Su 8-X-1991 Denmark 5-X-1961 21-VII-1976 R 19-IX-1976 Estonia 13-V-1998 A 12-VII-1998 Res Eswatini 23-XI-1970 A 22-I-1971 Res 9 Fiji 28-VI-1971 Su 10-X-1970 Res 9 Finland 13-III-1962 24-VI-1976 R 23-VIII-1976 France 9-X-1961 20-IX-1967 R 19-XI-1967 D,Res 10 Germany 5-X-1961 2-XI-1965 R 1-I-1966 Greece 5-X-1961 3-VI-1983 R 2-VIII-1983 Grenada 20-V-1985 Su 7-II-1974 Ireland 3-VIII-1967 A 2-X-1967 Israel 11-XI-1977 A 10-I-1978 Italy 15-XII-1961 Japan 30-I-1964 3-VI-1964 R 2-VIII-1964 Lesotho 1-VI-1977 Su 4-X-1966 Luxembourg 5-II-1968 7-XII-1978 R 5-II-1979 Res 1 Mauritius 24-VIII-1970 Su 12-III-1968 Montenegro 1-III-2007 Su 3-VI-2006 Netherlands (Kingdom of the) 17-III-1980 2-VI-1982 R 1-VIII-1982 1 Res North Macedonia 20-IX-1993 Su 17-XI-1991 Norway 5-X-1961 2-XI-1972 R 1-I-1973 Poland 3-IX-1969 A 2-XI-1969 D,Res 12 Portugal 29-IX-1967 Republic of Moldova 11-VIII-2011 A 10-X-2011 Res 9,10 Serbia 26-IV-2001 Su 27-IV-1992 D Slovenia 8-VI-1992 Su 25-VI-1991 South Africa 5-X-1970 A 4-XII-1970 Res 9,10,12 Spain 21-X-1976 11-IV-1988 R 10-VI-1988 Sweden 5-X-1961 9-VII-1976 R 7-IX-1976 Switzerland 9-IX-1970 18-VIII-1971 R 17-X-1971 Res 10 Tonga 10-VIII-1978 Su 4-VI-1970 Res 9,10 Türkiye 23-VIII-1983 A 22-X-1983 Res 9,10,12 Ukraine 15-III-2011 A 14-V-2011 Res 9,10,12 United Kingdom of Great Britain and Northern Ireland 13-II-1962 6-XI-1963 R 5-I-1964 10 D,Res 9 — Full contractingparties table — Checked: 2026-10-07