Preparing Redesigned Form 706-NA: Estate and Gift Tax Treaties, U.S. Situs Assets, Allowable Deductions

Like U.S. residents, the estate of a nonresident alien (NRA) is valued as of the date of death or using the alternative valuation date (six months later). An exemption is applied, and certain deductions are allowed before calculating the taxable estate. NRAs are also required to report the basis of assets transferred to beneficiaries using Form 8971. Unlike residents and citizens, the exemption applied is incredibly small — $60,000 compared to a resident's exemption of $15 million (as of 2026) — making planning critical for these taxpayers.

In September 2025, the IRS redesigned Form 706-NA to improve processing efficiency. Among the changes are the addition of page three, Part V, to report the Gross Estate in the United States, and the removal of the section in Part III for authorized representation; now, Form 2848, Power of Attorney, must be filed in place of the previous section. 

The revised form can be deceiving. It is simply three pages, divided into five parts. The number of required attachments and additional considerations increases the complexity of these filings. Trust and estate professionals working with multinational taxpayers need to understand how the estates of individuals located outside the U.S. are reported and taxed.

Listen as our panel of international estate tax experts explains the preparation of revised Form 706-NA and its other required forms, schedules, and attachments for nonresidents.