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Federal estate tax returns filed for nonresident aliens, 1999 and 2000.

The Federal tax system includes taxes on the right to transfer tangible and intangible property. The estate tax, part of the transfer taxes, is incurred when transferring property at death. This tax applies to the estates of U.S. citizens, resident aliens, and nonresident aliens who die owning property in the United States. The estate tax, whether incurred by estates of U.S. citizens, resident aliens, or nonresident aliens, is not a tax on an inheritance or on property. Instead, it is a tax on the right to transfer property at death.

For Filing Year 1999, the estate tax for U.S. citizens and resident aliens was incurred by estates in which decedents owned $650,000 or more in gross assets. However, the filing threshold of $650,000 increased to $675,000 in 2000 as a result of the Economic Recovery Tax Act (ERTA) of 1997. The estates of nonresident alien decedents have a filing threshold of $60,000 in U.S. gross assets. This threshold, established in 1988, did not increase with the ERTA of 1997. Tangible or real property that is owned by a nonresident alien and is physically located in the United States makes the asset part of the nonresident alien's U.S. gross estate. Intangible property, such as stocks or debt obligations, is included in a nonresident alien's estate based on the characteristics of the issuer or obligor. If the issuer of stock is a domestic corporation, or if the obligor of debt is a U.S. citizen or resident, domestic corporation, partnership, or Governmental unit, then the property is considered part of the nonresident alien's U.S. gross assets.

Although filing thresholds for estates of nonresident aliens differ from those of U.S. citizens and resident aliens, the same graduated and progressive tax rate structure is applied. The rate begins with 18 percent for the first $10,000 of adjusted taxable estate and continues to rise until it tops out at 55 percent for adjusted taxable estates of more than $3,000,000. The data collected by the Statistics of Income Division (SOI) of the Internal Revenue Service provide a snapshot of information about nonresident alien decedents, as well as the type and value of property that they hold in the United States.

For Filing Years 1999 and 2000, there were 990 Federal estate tax Forms 706NA filed for nonresident alien decedents. The returns received in 1999 and 2000 were not uniform in scope; therefore, different categories were created for analysis. The filing population of returns was broken into the following three categories: regular returns, treaty status returns, and incomplete or out-of-scope returns. Regular returns are filed by the estates of nonresident alien decedents who held assets in the United States worth $60,000 or more at the time of death. Treaty status returns were filed for nonresident aliens who held assets in the United States worth $60,000 or more at the time of death, but were domiciled in countries in which the United States has an applicable estate tax treaty. This means that these estates have different tax options that are not offered to regular return filers, such as a higher unified credit, or special deductions. Treaty status returns are often filed without dollar amounts or less information than regular returns, in part, due to varying reporting practices among countries. The incomplete returns are filed with missing pages or dollar amounts that prevent SOI review. Returns are considered out-of-scope if the estate held less than $60,000 in U.S. assets. For Filing Year 1999, SOI received 126 regular returns, 350 treaty status returns, and 76 incomplete or out-of-scope returns. SOI saw 113 regular returns, 290 treaty status returns, and 35 incomplete or out-of-scope returns for Filing Year 2000 (see Figure A). In this article, the incomplete and out-of-scope returns are excluded. The population is then comprised of regular and treaty returns. However, due to filing differences between these two types of returns, data tables will refer only to the regular returns, unless otherwise stated.

Regular Returns

The number of nonresident alien decedents whose estates filed a regular Form 706NA was 126 in 1999 and 113 in 2000 (see Figure B). However, the total gross estate in the United States of those that filed rose approximately from $60.7 million in 1999 to $132.4 million in 2000.

For both years, the highest percentage of nonresident alien estates was in the size of U.S. gross estate category $100,000 under $250,000. In 1999, about 37.3 percent of estates were in this range, while, in 2000, this percentage dropped to 35.4 percent. In 1999, about 15.9 percent of filers were in the largest gross estate category, $1 million or more, and this percentage dropped only slightly in 2000 to 15.0 percent.

For 1999, some 116 nonresident alien estates incurred an estate tax liability, and only 88 estates incurred tax liabilities for 2000. The estate tax for 1999 was nearly $14.7 million, while it increased greatly in 2000 to almost $30.8 million.

Citizenship Data

In Filing Year 1999, the average size of U.S. total gross estate was $552,541, where U.S. total gross estate is defined as the value of assets held in the United States and held by the decedent at the date of death (see Figure C). Afghanistan residents had the highest average size of U.S. total gross estate, almost $3.0 million, and a net estate tax of $765,829. Morocco had the second highest average gross estate, $2.1 million, and a higher net estate tax burden than Afghanistan, $818,646. The country with the third largest average U.S. gross estate was Portugal, which reported about $1.8 million in average gross estate. Israel had the fourth largest average size of U.S. total estate, $1.1 million, and a net estate tax liability of $1.4 million.

For Filing Year 2000, the average size of U.S. total gross estate increased to almost $1.5 million, and net estate tax liability rose to about $30.8 million. In Filing Year 2000, there were no estates that filed a Form 706NA from Afghanistan, the leader from 1999. Morocco had the largest average U.S. gross estate for 2000, almost $22.3 million, representing a large increase from the previous year. Morocco also had an increase in net estate tax liability, rising to $11.1 million from Filing Year 1999. In 2000, Israel had the second largest average U.S. gross estate, $18.2 million, and its net estate tax increased to $5.1 million. Hong Kong had the third largest average U.S. gross estate with about $2.7 million in gross assets, and a net estate tax liability of almost $3.7 million. Russia had the fourth largest average U.S. gross estate, just under $2 million, and a net estate tax of $746,200.

Demographic Data

For 1999 and 2000, the IRS received 126 and 113 regular returns, respectively. In both filing years, there were more male nonresident alien decedents than female nonresident alien decedents (see Figure D). For Filing Year 1999, the number of male decedents totaled 96 (76.2 percent of the total population of regular returns), while female decedents totaled only 30 (23.8 percent). Male decedents for Filing Year 2000 totaled 89 (78.8 percent of the total population of regular returns), and female decedents totaled only 24 (21.2 percent).

The burden of estate tax fell heavier on the estates of male decedents. This is due to the higher number of male decedents in the filing population for both 1999 and 2000. The estates of male decedents had 87.4 percent of the estate tax liability for Filing Year 1999, while the estates of female decedents held only 12.6 percent of the estate tax liability for 1999. The estates of male decedents reported $12.8 million in estate tax liability for 1999, and the estates of female decedents reported almost $1.9 million. This trend continued for Filing Year 2000. The estates of male decedents were responsible for 89 percent of the combined estate tax liability compared to the estates of female decedents, which were responsible for 11 percent. This represents $27.4 million in reported estate tax liability for male decedents and almost $3.4 million in reported liability for female decedents.

For Filing Year 1999, the average age at death for this nonresident alien estate tax population was 68 years (see Figure E). Average age at death increased by one year, to 69, for Filing Year 2000. The average life expectancy for the world in 2000 was 66 years, according to the World Heath Report from 2001 [1]. Therefore, the population of nonresident aliens exceeded the world average life expectancy. However, the population of nonresident aliens did not exceed the life expectancy of U.S. residents. The average life expectancy for a U.S. resident in 2000 was 76.7, according to the National Center for Health Statistics [2].

Asset Data

For the nonresident alien, the estate tax is applied to assets located in the United States at the time of death. For estate tax purposes, the values of the nonresident alien decedent's U.S. assets are based on the fair market value at one of two dates. The decedent's executor or administrator can value the assets at the date of the decedent's death or at an alternate valuation date within 6 months after the date of the decedent's death [3].

For Filing Year 1999, the estates of nonresident alien decedents held $25.9 million in real estate, which represented 44 percent of the combined U.S. total gross assets (see Figure F). Real estate holdings included personal residences, as well as the value of real estate partnerships or noncorporate businesses based on the ownership of real estate. This was the largest U.S. investment for this filing population. The second most prevalent asset type for this filing year of nonresident alien decedent population was stock. Stock accounted for $22.1 million of the combined U.S. gross assets, 36 percent of total assets for Filing Year 1999. The bonds and cash categories were the third largest of all the asset categories. These categories accounted for 5 percent of U.S. assets held by the estates of nonresident alien decedents in Filing Year 1999. Assets held in the form of bonds and cash totaled $3.1 million and almost $3.0 million, respectively.

For Filing Year 2000, stock not real estate was the largest category of assets held in the United States by the estates of nonresident alien decedents. Stock accounted for $57.8 million or 44 percent of the total U.S. assets held by the estates of nonresident alien decedents. Assets in the form of real estate were the second largest category of assets for Filing Year 2000. Assets in this form totaled $50.6 million or 38 percent of the total U.S. assets held by the estates of nonresident alien decedents. For Filing Year 2000, the "other" category had the third largest holdings. This category included the net value of insurance, depletables and intangibles, annuities, art, and assets that do not fit into any of the categories. The "other" category totaled $11.2 million, which equaled 9 percent of total assets for the estates of nonresident aliens.

Treaty Status Returns

The United States holds estate tax treaties with 18 countries: Australia, Austria, Canada, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Japan, Netherlands, Norway, Scotland, South Africa, Sweden, Switzerland, and the United Kingdom. The treaties may differ among countries, but the basic provisions provide mutual administration assistance between the U.S. and each country and avoid double taxation. This does not mean that the estates are not required to pay estate tax, but that they are given more tools to reduce the tax burden and, in some situations, reduce the tax burden to zero. Since these returns are different than the returns filed by estates from other non-treaty status countries, they are separated out for this study. They also exhibit different reporting practices, since executors follow the rules of the treaty and are not always required to list the dollar amount of assets. Figures G through J refer to returns with treaty status that reported dollar amounts.

Citizenship Data

Filing Year 1999 had 59 more treaty status returns than Filing Year 2000. This increase in returns filed was consistent across countries. Canada had the most decedents who owned assets in the United States at the date of death, 127 for 1999 and 124 for 2000 (see Figure G). The second highest number of estate filers came from Germany, with 70 returns for 1999 and 61 returns for 2000. The country with the third highest number of returns was the United Kingdom, with 59 returns for 1999 and 34 returns for 2000.

Canada, Germany, and the United Kingdom had the most filers for Filing Years 1999 and 2000. However, out of these three countries, Canada, with the largest number of returns filed, had the smallest average size of U.S. gross estate, only $220,721 for 1999 and $38,414 for 2000 (see Figure H). The United Kingdom ranked third for both 1999 and 2000 in the number of returns filed, but had the largest average size of U.S. gross estate, almost $4.6 million for 1999 and $695,760 for 2000.

The estates of United Kingdom decedents had the largest average size of U.S. gross estate. However, these estates had the smallest net estate tax liability for both 1999 and 2000. The net estate tax payable by United Kingdom estates for 1999 was $547,633 compared to the net estate tax payable for Canada, $5.0 million, and Germany, $3.4 million. For Filing Year 2000, the United Kingdom had a net estate tax liability of $293,309, while Canada and Germany had net estate tax liabilities of $1.7 million and $635,069, respectively.

Unified Credit

Part 2, line 7 of Form 706NA is the line on which the estate of the decedent reports the unified credit. The unified credit is applied against the tax imposed on the estate. In general, the maximum unified credit is $13,000; however, the maximum unified credit may be more than $13,000 if, on the decedent's date of death, he or she was domiciled in a country that holds a treaty with the United States. The tax code allows for these estates to use a unified credit equal to the amount equivalent to the same ratio of credit allowed to the estate of a U.S. citizen. The numerator of the ratio is the value of the decedent's gross estate located within the United States, and the denominator is the decedent's entire gross estate wherever situated. This ratio allows the estates of these nonresident alien decedents to lower their total gross estates and thus lower the estate tax.

The estates of nonresident alien decedents domiciled in Australia at the date of death had the highest average unified credit for Filing Year 1999, about $82,099 (see Figure I). Returns filed with estates domiciled in Switzerland had the second highest average unified credit, $50,872 for Filing Year 1999. The third highest average unified credit was from estates domiciled in Italy, with $42,079.

For Filing Year 2000, the top two countries with the highest average unified credit were different than those from the previous year. Estates from Japan had the highest average unified credit, with $34,699, and the second highest average unified credit of $27,658 was from estates domiciled in Canada. Switzerland, which had the third highest average unified credit in 2000, about $26,492, dropped from having the second highest average unified credit in 1999.

Asset Data

The population of nonresident alien decedents domiciled in a country that maintains an estate tax treaty with the United States reported owning a total of $123.7 million in U.S. assets at the date of death, or within 6 months thereafter, for Filing Year 1999. Out of the total assets from treaty status returns, $43.5 million or 49 percent were in the form of real estate (see Figure J). This is the same percentage as for returns filed by the estates of nonresident alien decedents who were not domiciled in a treaty status country at the date of death.

Stock was the second largest type of asset held in the United States, almost $26.3 million, or 30 percent of the total. However, the similarities between the regular return filers and the treaty status filers end with the third largest category of assets, which was the noncorporate business assets category. For Filing Year 1999, noncorporate business assets totaled $6.8 million, which was 8 percent of total assets held in United States treaty status estates.

For Filing Year 2000, the total U.S. assets reported by estates of nonresident alien decedents domiciled in a country in which an estate tax treaty is held with the United States were lower than the previous year, down to $74.3 million from $123.7 million. There were some similarities between nonresident alien estates filing in 1999 and 2000; however, the top three categories with the largest amount of assets were not the same for the treaty status returns and the regular returns for Filing Year 2000. The largest type of asset reported on treaty status returns in Filing Year 2000 was real estate, which amounted to $39.5 million and comprised 55 percent of total assets. The second largest type of asset held in 2000 for treaty status returns was stock. The total value of the stock held was $17.8 million, and this was 24 percent of total assets held in the United States by treaty status nonresident aliens at death. The third largest category of assets was in the forms of "other" and noncorporate business assets. This is a slight change from the previous year in which the "other" category was the sole asset in this position. Both of these assets accounted for 7 percent of total assets. Noncorporate business assets totaled $4.9 million, whereas "other" assets totaled $5.2 million.

Data Sources and Limitations

Since 1995, SOI has conducted an annual study of Federal estate tax returns filed for nonresident aliens (Forms 706NA). The demographic, financial, and asset information for the 1999 and 2000 filing years was extracted from Forms 706NA that are filed in the Philadelphia Submission Processing Center. For each year, nonresident alien estate tax returns were examined for the population of filers. Therefore, the amounts shown in this article are not estimates but rather pre-audit population figures.

The United States maintains estate and gift tax treaties with a number of countries. These treaties are in place to help avoid double taxation and to provide mutual administrative assistance between the United States and its treaty partners. The reporting on these returns varies among the countries. Therefore, the information extracted from these Forms 706NA explicitly identified as treaty returns in Filing Years 1999 and 2000 is separated from the regular returns.

Explanation of Selected Terms

Brief definitions of some of the terms used in the text and tables are provided below:

Adjusted taxable estate.--Adjusted taxable estate is equal to the sum of taxable estate and adjusted taxable girls.

Adjusted taxable gifts.--Certain girls of tangible or intangible property located in the United States and made during the life of an individual who died before 1982 were automatically included in gross estate. However, for the estate of an individual who died after 1981, these gifts were not generally included in the gross estate. Instead, they were added to the taxable estate, creating the "adjusted taxable estate" for the purposes of determining the "estate tax before credits."

Charitable deduction.--This was the deduction allowable for a decedent's contributions to qualifying charitable organizations.

Estate tax before credits.--This was the tax obtained by applying the graduated estate tax rates to the adjusted taxable estate reduced by the amount of Federal gift taxes previously paid.

Federal girl taxes previously paid.--Credit was allowed against the estate tax for the Federal gift tax paid on gifts made by a decedent before 1977. No credit, apart from the unified credit, was allowed for any gift tax paid on gifts made after 1976.

Marital deduction.--This is equal to the value of property interests passing from the decedent to the surviving spouse and was taken as a deduction from the "total gross estate." Unless an estate tax treaty allows otherwise, the marital deduction was allowed only if the surviving spouse was a U.S. citizen or if the property passed to a qualified domestic trust (QDOT) described in IRC section 2056A.

Net estate tax.--This was the estate's tax liability after credits for State death taxes, foreign death taxes, tax on prior transfers, and Federal gift taxes previously paid were subtracted from gross estate tax. In addition to these credits, a "unified credit," graduated according to the year of death, and a "credit" for gift taxes paid on post-1976 gifts, are allowed (see also "unified credit").

Nonresident alien decedent.--A nonresident alien decedent is neither domiciled in, nor a citizen of, the United States at the time of death. According to IRS definition, a citizen of a U.S. possession is not a U.S. citizen.

Nontaxable returns.--Nontaxable returns were those with no estate tax liability after credits.

Other tax credits.--This was the sum of the tax credits for death taxes paid to foreign governments and Federal gift taxes previously paid. It also included a tax credit for Federal estate tax paid on property received by the decedent or the estate from a transferor who died within 10 years before, or 2 years after, the decedent. This credit was intended to lessen the burden of double taxation between successive estates whose owners had died within a short period of time. Depending on the time that elapsed between the deaths, a credit was allowed for all or part of the Federal estate tax paid by the transferor's estate with respect to the transfer.

Tax on prior transfers.--A tax credit was allowed for Federal estate tax paid on property received by the decedent or the estate from a transferor who died within 10 years before, or 2 years after, the decedent. The credit was intended to lessen the burden of double taxation between successive estates whose owners had died within a short period of time. Depending on the time that elapsed between the deaths, a credit was allowed for all or part of the Federal estate tax paid by the transferor's estate with respect to the transfer.

Taxable estate.--Taxable estate was the base to which the graduated Federal estate tax rates were applied in computing the estate tax before credits. Taxable estate is equal to the value of the "total gross estate" less deductions for the following: funeral and administrative expenses; casualty and theft losses; debts, mortgages, losses, and other claims against the estate, including pledges to charitable organizations; bequests to the surviving spouse; and the "employee stock ownership plan" (ESOP) deduction (included in the statistics for "other expenses and losses").

Taxable returns.--Taxable returns were those with estate tax liability after credits.

Unified credit.--The unified credit, so called because it is used for both estate and gift tax purposes, is applied as a dollar-for-dollar reduction of the estate tax. (The unified credit represents the amount of tax on that part of gross estate which is below the filing requirement.) The credit must be used to offset gift taxes on lifetime transfers made after 1976. However, to the extent it is so used, the amount of credit available at death is reduced.
Table 1.--Nonresident Alien Estate Tax Returns Filed in 1999: Gross
Estate in the U.S., Outside the U.S., and Worldwide, and U.S. Gross
Estate by Type of Property, Deductions, Taxable Estate, Estate Tax,
and Tax Credits, by Tax Status and Size of U.S. Gross Estate

[Money amounts are in whole dollars]

 Total gross
 estate, U.S., tax Total gross estate,
 puposes (1) outside the U.S.

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (1) (2) (3) (4)

 All returns, total 126 60,687,546 126 61,263,445
Less than $100,000 17 1,364,556 17 13,265,172
$100,000 under
 $500,000 71 16,567,962 71 27,215,168
$500,000 or more 38 42,755,028 38 20,783,105

 Nontaxable returns,
 total 10 2,746,878 10 1,108,636
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** 10 ** 2,746,878 ** 10 ** 1,108,636
$500,000 or more ** ** ** **

 Taxable returns,
 total 116 57,940,668 116 60,154,809
Less than $100,000 15 1,242,354 15 12,865,172
$100,000 under
 $500,000 64 14,780,479 64 26,506,532
$500,000 or more 37 41,917,835 37 20,783,105

 Total gross estate,
 worldwide Real estate (2)

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (5) (6) (7) (8)

 All returns, total 126 121,950,991 84 25,891,245
Less than $100,000 17 14,629,728 12 904,772
$100,000 under
 $500,000 71 43,783,130 52 6,233,316
$500,000 or more 38 63,538,133 20 14,383,157

 Nontaxable returns,
 total 10 3,855,514 7 1,623,670
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** 10 ** 3,855,514 ** 7 ** 1,623,670
$500,000 or more ** ** ** **

 Taxable returns,
 total 116 118,095,477 77 24,267,575
Less than $100,000 15 14,107,526 11 841,022
$100,000 under
 $500,000 64 41,287,011 47 9,518,396
$500,000 or more 37 62,700,940 19 13,908,157

 Stock (3) Bonds (4)

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (9) (10) (11) (12)

 All returns, total 53 22,062,058 21 3,079,029
Less than $100,000 ** ** 3 52,000
$100,000 under
 $500,000 ** 27 ** 4,452,978 5 161,706
$500,000 or more 26 17,609,080 13 2,865,323

 Nontaxable returns,
 total ** ** -- --
Less than $100,000 ** ** -- --
$100,000 under
 $500,000 ** ** -- --
$500,000 or more ** ** -- --

 Taxable returns,
 total 53 22,062,058 21 3,079,029
Less than $100,000 ** ** 3 52,000
$100,000 under
 $500,000 ** 27 ** 4,452,978 5 161,706
$500,000 or more 26 17,609,080 13 2,865,323

 Mixed mutual
 funds (5) Cash

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (13) (14) (15) (16)

 All returns, total 7 2,056,733 22 2,951,047
Less than $100,000 -- -- ** **
$100,000 under
 $500,000 ** ** ** 8 ** 446,378
$500,000 or more ** 7 ** 2,056,733 14 2,446,217

 Nontaxable returns,
 total ** ** ** **
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** ** ** **
$500,000 or more ** ** ** **

 Taxable returns,
 total 7 2,056,733 22 2,951,047
Less than $100,000 ** ** -- --
$100,000 under
 $500,000 ** ** ** 8 ** 446,378
$500,000 or more ** 7 ** 2,056,733 14 2,446,217

 Money market Insurance,
 accounts (6) net value

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (17) (18) (19) (20)

 All returns, total 13 2,313,658 ** **
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** 6 ** 944,809 ** **
$500,000 or more 7 1,368,849 ** **

 Nontaxable returns,
 total ** ** -- --
Less than $100,000 ** ** -- --
$100,000 under
 $500,000 ** ** -- --
$500,000 or more ** ** -- --

 Taxable returns,
 total ** 13 ** 2,313,658 ** **
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** 6 ** 944,809 ** **
$500,000 or more 7 1,015,740 ** **

 Noncorporate Mortgages
 business assets (7) and notes

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (21) (22) (23) (24)

 All returns, total 5 1,382,567 6 96,544
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** ** ** 6 ** 96,544
$500,000 or more ** 5 ** 1,382,567 -- --

 Nontaxable returns,
 total ** ** ** **
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** ** ** **
$500,000 or more ** ** ** **

 Taxable returns,
 total 5 1,382,567 6 96,544
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** ** ** 6 ** 96,544
$500,000 or more ** 5 ** 1,382,567 -- --

 Other assets Funeral expenses

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (25) (26) (27) (28)

 All returns, total 28 492,290 35 271,463
Less than $100,000 3 47,061 5 31,058
$100,000 under
 $500,000 18 227,561 17 97,786
$500,000 or more 7 217,668 13 142,619

 Nontaxable returns,
 total -- -- 3 30,820
Less than $100,000 -- -- ** **
$100,000 under
 $500,000 -- -- ** 3 ** 30,820
$500,000 or more -- -- -- --

 Taxable returns,
 total 28 492,290 32 240,643
Less than $100,000 3 47,061 4 14,588
$100,000 under
 $500,000 18 227,561 13 83,466
$500,000 or more 7 217,668 15 142,619

 Executors'
 commissions Attorneys' fees

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (29) (30) (31) (32)

 All returns, total 10 918,772 40 1,109,096
Less than $100,000 -- -- 4 14,210
$100,000 under
 $500,000 4 601,772 21 240,144
$500,000 or more 6 317,000 15 854,742

 Nontaxable returns,
 total ** ** 5 26,425
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** ** ** 5 ** 26,425
$500,000 or more ** ** -- --

 Taxable returns,
 total ** 10 ** 918,772 35 1,082,671
Less than $100,000 -- -- 3 13,485
$100,000 under
 $500,000 ** 4 ** 601,772 17 214,444
$500,000 or more 6 317,000 15 854,742

 Other expenses/
 losses Debts and mortgages

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (33) (34) (35) (36)

 All returns, total 56 2,510,638 33 6,826,005
Less than $100,000 7 463,337 ** **
$100,000 under
 $500,000 28 1,160,770 ** 21 ** 1,909,868
$500,000 or more 21 8,886,531 12 4,916,280

 Nontaxable returns,
 total 4 30,099 6 883,204
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** 4 30,099 ** 6 ** 883,204
$500,000 or more -- ** -- --

 Taxable returns,
 total 52 2,480,539 27 5,942,801
Less than $100,000 6 454,669 ** **
$100,000 under
 $500,000 25 1,139,339 ** 15 ** 1,026,521
$500,000 or more 21 886,531 12 4,916,280

 Marital and
 charitable Total allowable
 deductions deductions

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (37) (38) (39) (40)

 All returns, total 9 3,211,518 64 9,235,166
Less than $100,000 ** ** 7 25,535
$100,000 under
 $500,000 ** ** 34 3,148,870
$500,000 or more ** 9 ** 3,211,518 23 7,060,761

 Nontaxable returns,
 total 3 1,068,181 7 1,787,771
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** ** ** 7 ** 1,787,771
$500,000 or more ** 3 ** 1,068,181 ** **

 Taxable returns,
 total 6 2,143,337 57 7,447,395
Less than $100,000 ** ** 6 20,758
$100,000 under
 $500,000 ** ** 29 1,203,069
$500,000 or more ** 6 ** 2,143,337 22 6,223,568

 Adjusted taxable
 Taxable estate estate

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (41) (42) (43) (44)

 All returns, total 124 51,500,230 124 51,600,309
Less than $100,000 ** 17 ** 1,339,024 17 1,339,024
$100,000 under
 $500,000 70 14,466,941 70 14,567,020
$500,000 or more 37 35,694,265 37 35,694,265

 Nontaxable returns,
 total 8 1,006,956 8 1,006,956
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** 5 ** 446,398 ** 8 ** 1,006,956
$500,000 or more 3 560,766 -- --

 Taxable returns,
 total 116 50,493,274 116 50,593,353
Less than $100,000 15 1,221,599 15 1,221,599
$100,000 under
 $500,000 64 13,577,410 64 7,764,489
$500,000 or more 37 35,694,265 37 35,694,262

 Estate tax before Allowable unified
 credits credit

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (45) (46) (47) (48)

 All returns, total 122 16,830,610 123 1,627,804
Less than $100,000 17 293,219 17 211,354
$100,000 under
 $500,000 68 3,844,724 69 905,980
$500,000 or more 37 12,692,667 37 510,470

 Nontaxable returns,
 total 6 65,270 7 79,554
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** 6 ** 65,270 ** 7 ** 79,554
$500,000 or more -- -- -- **

 Taxable returns,
 total 116 16,765,340 116 1,548,250
Less than $100,000 15 267,837 15 185,600
$100,000 under
 $500,000 64 3,804,836 64 849,180
$500,000 or more 37 12,692,667 37 510,470

 State death
 tax credit Other credits

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (49) (50) (51) (52)

 All returns, total 50 518,717 ** **
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** 34 ** 69,215 ** **
$500,000 or more 16 449,502 ** **

 Nontaxable returns,
 total -- -- -- --

 Taxable returns,
 total 50 518,717 ** **
Less than $100,000 ** ** ** **
$100,000 under
 $500,000 ** 34 ** 69,215 ** **
$500,000 or more 16 449,502 ** **

 Estate tax

 Tax status, size of
 U.S. gross estate Number Amount

 (53) (54)

 All returns, total 116 14,680,834
Less than $100,000 15 81,363
$100,000 under
 $500,000 64 2,866,777
$500,000 or more 37 11,732,694

 Nontaxable returns,
 total -- --

 Taxable returns,
 total 116 14,680,834
Less than $100,000 15 81,363
$100,000 under
 $500,000 64 2,866,777
$500,000 or more 37 11,732,694

** Data deleted or combined to prevent disclosure of individual
taxpayer data. However, the data are included in the appropriate
totals.

(1) Gross estate is shown at the value used to determine estate tax
liability. The value can be calculated at the date of death or within
6 months thereafter (alternate valuation method).

(2) Real estate category includes the value of all real estate, the
value of personal residences, and the value of real estate
partnerships.

(3) Stock category contains the value of corporate stock and stock in
a closely held corporation. The value of mutual funds that are
comprised mainly of stock is also included.

(4) Bonds category contains the value of Federal, State, and local
government bonds, as well as foreign and corporate bonds. The value of
mutual funds that are comprised of Federal, State, local government,
foreign, and corporate bonds are also included.

(5) Mixed mutual funds category contains the value of funds that
contain assets that are not identified. Therefore, this category may
contain the value of stock, bonds, and other assets in mutual funds.

(6) Money market accounts category contains cash management accounts,
ready asset accounts, and other banking or checking type accounts
held as mutual funds.

(7) The noncorporate business category includes the value of farm
assets, limited partnerships, and other noncorporate business assets.

NOTE: Detail may not add to totals due to rounding.

Table 2.--Nonresident Alien Estate Tax Returns Filed in 2000: Gross
Estate in the U.S., Outside the U.S., and Worldwide, and U.S. Gross
Estate by Type of Property, Deductions, Taxable Estate, Estate Tax, and
Tax Credits by Tax Status and Size of U.S. Gross Estate

[Money amounts are in whole dollars]

 Total gross estate,
 U.S., tax Total gross estate,
 purposes (1) outside the U.S.

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (1) (2) (3) (4)

 All returns, total 113 132,394,135 113 73,527,680
Less than $100,000 24 1,862,003 24 4,379,557
$100,000 under $500,000 59 12,695,599 59 53,626,712
$500,000 or more 30 117,836,533 30 15,521,411

 Nontaxable returns,
 total 25 9,532,632 25 31,942,357
Less than $100,000 9 676,841 9 846,112
$100,000 under $500,000 10 2,646,195 10 29,643,132
$500,000 or more 6 6,209,596 6 1,453,113

 Taxable returns,
 total 88 122,861,503 88 41,585,323
Less than $100,000 15 1,185,162 15 3,533,445
$100,000 under $500,000 49 10,049,404 49 23,983,580
$500,000 or more 24 111,626,937 24 14,068,298

 Total gross estate,
 worldwide Real estate (2)

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (5) (6) (7) (8)

 All returns, total 113 205,921,814 65 50,664,178
Less than $100,000 24 6,241,560 18 1,235,395
$100,000 under $500,000 59 66,322,309 26 4,423,081
$500,000 or more 30 133,357,945 18 44,637,379

 Nontaxable returns,
 total 25 41,474,989 20 4,609,573
Less than $100,000 9 1,522,953 8 564,830
$100,000 under $500,000 10 32,289,327 8 1,832,155
$500,000 or more 6 7,662,709 4 2,212,000

 Taxable returns,
 total 88 164,446,825 45 46,054,605
Less than $100,000 15 4,718,607 11 735,169
$100,000 under $500,000 49 34,032,982 30 2,894,645
$500,000 or more 24 125,695,236 14 42,424,791

 Stock (3) Bonds (4)

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (9) (10) (11) (12)

 All returns, total 55 57,848,565 16 1,162,256
Less than $100,000 7 330,955 2 9,893
$100,000 under $500,000 30 5,451,434 11 884,500
$500,000 or more 17 51,668,516 3 267,863

 Nontaxable returns,
 total 8 3,257,879 4 365,492
Less than $100,000 ** ** -- --
$100,000 under $500,000 ** 3 ** 522,842 ** 4 ** 365,492
$500,000 or more 5 2,735,037 ** **

 Taxable returns,
 total 47 54,590,686 12 796,764
Less than $100,000 6 231,226 ** **
$100,000 under $500,000 28 5,028,321 ** 12 ** 796,764
$500,000 or more 13 49,331,139 ** **

 Mixed mutual
 funds (5) Cash

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (13) (14) (15) (16)

 All returns, total 8 2,964,136 25 3,148,123
Less than $100,000 ** ** 4 80,176
$100,000 under $500,000 ** 8 ** 2,964,136 13 397,761
$500,000 or more ** ** 8 2,670,186

 Nontaxable returns,
 total ** ** 3 142,611
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** ** ** 3 ** 142,611
$500,000 or more ** ** ** **

 Taxable returns,
 total ** 8 ** 2,964,136 22 3,005,612
Less than $100,000 ** ** 3 78,594
$100,000 under $500,000 ** 8 ** 2,964,136 12 289,869
$500,000 or more ** ** 7 2,637,049

 Money market Insurance, net
 accounts (6) value

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (17) (18) (19) (20)

 All returns, total 11 430,914 ** **
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** 11 ** 430,914 ** **
$500,000 or more ** ** ** **

 Nontaxable returns,
 total ** ** -- --
Less than $100,000 ** ** -- --
$100,000 under $500,000 ** ** -- --
$500,000 or more ** ** -- --

 Taxable returns,
 total ** 11 ** 430,914 ** **
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** 11 ** 430,914 ** **
$500,000 or more ** ** ** **

 Noncorporate
 business assets (7) Mortgages and notes

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (21) (22) (23) (24)

 All returns, total 9 3,436,590 3 1,480,626
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** ** ** 3 ** 1,480,626
$500,000 or more ** 9 ** 3,436,590 ** **

 Nontaxable returns,
 total 3 173,650 -- --
Less than $100,000 -- -- -- --
$100,000 under $500,000 ** ** -- --
$500,000 or more ** ** -- --

 Taxable returns,
 total 6 3,262,940 3 1,480,626
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** ** ** 3 ** 1,480,626
$500,000 or more ** 6 ** 3,262,940 ** **

 Other assets Funeral expenses

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (25) (26) (27) (28)

 All returns, total 21 10,495,844 28 186,388
Less than $100,000 3 10,753 4 10,040
$100,000 under $500,000 10 309,994 14 73,580
$500,000 or more 8 10,175,097 10 102,768

 Nontaxable returns,
 total 5 368,110 6 36,381
Less than $100,000 ** ** 3 8,140
$100,000 under $500,000 ** 5 ** 368,110 3 28,241
$500,000 or more ** ***

 Taxable returns,
 total 16 10,127,734 22 150,007
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** 9 ** 302,322 ** 12 ** 47,239
$500,000 or more 7 9,825,412 10 102,768

 Executors'
 commissions Attorneys' fees

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (29) (30) (31) (32)

 All returns, total 7 294,398 21 307,590
Less than $100,000 -- -- ** 6,853
$100,000 under $500,000 ** ** ** 14 ** 138,874
$500,000 or more ** 7 ** 294,398 6 168,716

 Nontaxable returns,
 total -- -- 6 32,353
Less than $100,000 -- -- ** **
$100,000 under $500,000 -- -- ** 6 ** 32,353
$500,000 or more -- -- -- --

 Taxable returns,
 total 7 294,398 15 275,237
Less than $100,000 -- -- -- --
$100,000 under $500,000 ** ** 9 106,521
$500,000 or more ** 7 ** 294,398 6 168,716

 Other expenses/
 losses Debts and mortgages

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (33) (34) (35) (36)

 All returns, total 50 1,938,247 19 2,895,367
Less than $100,000 10 49,784 6 340,896
$100,000 under $500,000 25 549,685 6 324,137
$500,000 or more 15 1,338,778 5 2,230,334

 Nontaxable returns,
 total 14 1,061,730 8 437,732
Less than $100,000 6 13,858 ** 8 ** 437,732
$100,000 under $500,000 ** 7 ** 1,017,872 ** **
$500,000 or more ** ** ** **

 Taxable returns,
 total 36 876,517 11 2,457,635
Less than $100,000 4 35,926 -- --
$100,000 under $500,000 19 367,980 6 227,301
$500,000 or more 13 472,611 5 2,230,334

 Marital and charitable Total allowable
 deductions deductions

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (37) (38) (39) (40)

 All returns, total 17 54,066,932 65 56,981,875
Less than $100,000 -- -- 12 211,527
$100,000 under $500,000 9 2,506,600 32 3,058,937
$500,000 or more 8 51,560,332 21 53,711,411

 Nontaxable returns,
 total 13 9,144,043 24 10,453,554
Less than $100,000 -- -- 8 186,298
$100,000 under $500,000 7 2,403,885 10 2,719,585
$500,000 or more 6 20,490,158 6 7,547,671

 Taxable returns,
 total 4 44,922,889 41 46,528,321
Less than $100,000 -- -- 4 25,229
$100,000 under $500,000 ** ** 22 339,352
$500,000 or more ** 4 ** 44,9228,889 15 46,163,740

 Adjusted taxable
 Taxable estate estate

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (41) (42) (43) (44)

 All returns, total 103 77,033,030 103 77,033,030
Less than $100,000 23 1,550,996 23 1,550,996
$100,000 under $500,000 53 9,903,366 53 9,903,366
$500,000 or more 27 65,578,668 27 65,578,668

 Nontaxable returns,
 total 15 735,058 15 735,058
Less than $100,000 8 390,812 8 390,812
$100,000 under $500,000 4 193,306 4 193,306
$500,000 or more 3 150,941 3 150,940

 Taxable returns,
 total 88 76,297,972 88 76,297,972
Less than $100,000 15 1,160,184 15 1,160,184
$100,000 under $500,000 49 9,710,060 49 9,710,060
$500,000 or more 24 65,427,728 24 65,427,728

 Estate tax before Allowable unified
 credits credit

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (45) (46) (47) (48)

 All returns, total 103 34,455,687 101 1,498,001
Less than $100,000 23 346,404 23 277,875
$100,000 under $500,000 53 2,718,895 51 650,237
$500,000 or more 27 31,390,388 27 569,889

 Nontaxable returns,
 total 15 152,767 15 153,829
Less than $100,000 8 82,875 8 82,875
$100,000 under $500,000 4 37,732 4 38,238
$500,000 or more 3 32,160 3 64,876

 Taxable returns,
 total 88 34,302,920 86 1,344,172
Less than $100,000 15 263,529 15 195,000
$100,000 under $500,000 49 2,681,163 47 611,999
$500,000 or more 24 31,358,228 24 537,173

 State death tax
 credit Other credits

 Tax status, size of
 U.S. gross estate Number Amount Number Amount

 (49) (50) (51) (52)

 All returns, total 30 2,173,368 ** **
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** 17 ** 28,624 ** **
$500,000 or more 13 2,144,744 ** **

 Nontaxable returns,
 total -- -- -- --

 Taxable returns,
 total 30 2,173,368 ** **
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** 17 ** 28,624 ** **
$500,000 or more 13 2,144,744 ** **

 Estate tax

 Tax status, size of
 U.S. gross estate Number Amount

 (53) (54)

 All returns, total 88 30,781,044
Less than $100,000 15 68,415
$100,000 under $500,000 49 2,036,318
$500,000 or more 24 28,676,311

 Nontaxable returns,
 total -- --

 Taxable returns,
 total 88 30,781,044
Less than $100,000 15 68,415
$100,000 under $500,000 49 2,036,318
$500,000 or more 24 28,676,311

** Data deleted or combined to prevent disclosure of individual
taxpayer data. However, the data are included in the appropriate
totals.

(1) Gross estate is shown at the value used to determine estate tax
liability. The value can be calculated at the date of death or within
6 months thereafter (alternate valuation method).

(2) Real estate category includes the value of all real estate, the
value of personal residences, and the value of real estate
partnerships.

(3) Stock category contains the value of corporate stock and stock in
a closely held corporation. The value of mutual funds that are
comprised mainly of stock is also included.

(4) Bonds category contains the value of Federal, State, and local
government bonds, as well as foreign and corporate bonds. The value of
mutual funds that are comprised of Federal, State, local government,
foreign, and corporate bonds are also included.

(5) Mixed mutual funds category contains the value of funds that
contain assets that are not identified. Therefore, this category may
contain the value of stock, bonds, and other assets in mutual funds.

(6) Money market accounts category contains cash management accounts,
ready asset accounts, and other banking or checking type accounts held
as mutual funds.

(7) The noncorporate business category includes the value of farm
assets, limited partnerships, and other noncorporate business assets.

NOTE: Detail may not add to totals due to rounding.

Figure A
Form 706NA Returns Filed in 1999 and 2000, by
Type of Return

 1999 2000

 Number Percentage Number Percentage
 Type of return of of of of
 returns total returns total

 (1) (2) (3) (4)

 Total 552 100.0 438 100.0
Regular 126 22.8 113 25.8
Treaty status 350 63.4 290 66.2
Incomplete/out-of-scope 76 13.8 35 8.0

Figure B
Form 706NA Returns Filed in 1999 and 2000: Number of Returns and U.S.
Total Gross Estate, by Size of U.S. Total Gross Estate

 U.S. total gross estate, tax purposes

 1999

 Size of U.S. Number Percentage
 total gross estate of of Amount
 returns total

 Total 126 86.5 60,687,546
Less than $60,000 (1) ** ** **
$60,000 under $100,000 ** 17 ** 13.5 ** 1,364,556
$100,000 under $250,000 47 37.3 7,820,708
$250,000 under $500,000 24 19.0 8,747,254
$500,000 under $1 million 18 14.3 12,761,792
$1 million or more 20 15.9 29,993,236

 U.S. total gross estate, tax purposes

 2000

 Size of U.S. Number Percentage
 total gross estate of of Amount
 returns total

 Total 113 100.0 132,394,135
Less than $60,000 (1) -- -- --
$60,000 under $100,000 24 21.2 1,862,003
$100,000 under $250,000 40 35.4 6,056,061
$250,000 under $500,000 19 16.8 6,639,538
$500,000 under $1 million 13 11.5 8,577,795
$1 million or more 17 15.0 109,258,738

** Data deleted or combined to prevent disclosure of individual
taxpayer data. However, the data are included in the appropriate
totals.

(1) Due to alternate valuation, some estates fall below the filing
threshold.

Figure C
Form 706NA Returns: Average Size of U.S. Total Gross Estate and Net
Estate Tax, by Domicile at Death, Filing Years 1999 and 2000

 1999 2000

 U.S. U.S.
 total total
 gross gross
Domicile at death estate, Net estate estate, Net estate
 average tax average tax
 (1) (1)

 (1) (2) (3) (4)

 All countries 552,541 14,680,834 1,470,131 30,781,044
Afghanistan 2,952,405 765,829 -- --
Antibes -- -- 1,539,781 510,519
Argentina 179,181 139,209 474,202 277,102
Bahamas 294,426 130,680 349,875 91,758
Belgium 220,567 146,859 519,299 565,665

Bermuda -- -- 283,465 45,655
Bolivia 302,391 75,612 -- --
Brazil 754,464 1,125,505 114,230 11,530
Chile -- -- 183,621 28,770
China 133,420 -- -- --

Colombia 206,059 861,969 133,776 63,715
Costa Rica 58,452 -- -- --
Crans-Pres-Celgny 180,000 35,400 -- --
Cyprus 200,991 71,828 -- --
Czech Republic -- -- 136,111 21,633

Dubai 61,094 284 1,248,649 --
Ecuador -- -- 118,125 25,400
El Salvador 227,053 146,708 -- --
Ethiopia -- -- 141,671 23,301
Guatemala 302,500 71,970 -- --

Honduras 113,000 14,596 -- --
Hong Kong 676,252 896,343 2,692,105 3,764,342
India 651,880 198,996 202,154 171,360
Iran 215,000 45,040 -- --
Israel 1,139,686 1,361,064 18,216,554 5,107,149

Jamaica -- -- 74,750 --
Korea 77,500 4,550 -- --
Lebanon 160,654 29,209 725,611 --
Mexico 272,510 819,457 413,908 523,620
Morocco 2,103,768 818,646 22,279,520 11,127,286

New Zealand 717,081 890,857 564,144 105,186
Nicaragua -- -- 171,350 31,890
Nigeria 490,000 -- -- --
Orient -- -- 200,753 37,223
Pakistan -- -- 289,432 71,207

Panama -- -- 119,205 29,259
Peru -- -- 76,029 4,168
Philippines 174,550 95,179 90,130 4,829
Portugal 1,780,000 543,067 -- --
Puerto Rico 727,586 1,923,275 87,166 5,027,829

Rua Alvorado -- -- 480,560 136,190
Russia 909,872 823,458 1,952,000 746,200
San Pedro -- -- 61,250 325
San Salvador -- -- 787,970 453,390
Saudi Arabia 939,763 133,203 737,024 494,750

Singapore -- -- 233,056 103,956
Spain 599,950 1,166,827 345,158 327,146
Sri Lanka 408,691 80,214 -- --
Taiwan 604,488 478,001 410,367 43,771
Tokelau -- -- 151,425 23,456

Trinidad -- -- 92,265 17,657
Venezuela 245,976 687,978 256,415 763,807
Virgin Islands 98,894 8,641 382,023 --
West Indies 711,388 90,380 -- --

(1) Gross estate is shown at the value used to determine estate tax
liability. The value could be determined as of date of death or within
6 months thereafter (i.e., alternate valuation method).

Figure D
Form 706NA Returns Filed in 1999 and 2000: Selected Items, by Sex of
Decedent

 U.S. total gross estate,
 tax purposes (1)

 1999

 Number
 Sex of of Percentage Amount
decedent returns of total

 (1) (2) (3)


Total 126 100.0 60,687,546
Female 30 23.8 8,609,791
Male 96 76.2 52,077,755

 U.S. total gross estate,
 tax purposes (1)

 2000

 Number
 Sex of of Percentage Amount
decedent returns of total

 (4) (5) (6)

Total 113 100.0 132,394,135
Female 24 21.2 13,373,923
Male 89 78.8 119,020,212

 Net estate tax

 1999 2000

 Sex of Amount Percentage Amount Percentage
decedent of total of total

 (7) (8) (9) (10)

Total 14,680,834 100.0 30,781,044 100.0
Female 1,848,811 12.6 3,371,196 11.0
Male 12,832,023 87.4 27,409,848 89.0

(1) Gross estate is shown at the value used to determine estate tax
liability. The value could be determined as of date of death or within
6 months thereafter (i.e., alternate valuation method).

Figure E
Form 706NA Returns Filed in 1999 and 2000,
by Sex of Decedent and Average Age

 1999 2000

Sex of Number Average Number Average
decedent of returns age of returns age

 (1) (2) (3) (4)

 All 126 68 113 69
Female 30 68 24 72
Male 96 68 89 68

Figure F
Form 706NA Returns: Composition of U.S. Total Gross Estate, Filing
Years 1999 and 2000 (1)

1999

$60.7 Million

Real estate (2) 44%
Stock (3) 36%
Bonds (4) 5%
Mixed mutual funds (5) 3%
Cash 5%
Money market accounts (6) 4%
Noncorporate business assets 2%
Other (7) 1%

2000

$132.4 Million

Real estate (2) 38%
Stock (3) 44%
Bonds (4) 1%
Mixed mutual funds (5) 2%
Cash 2%
Mortgages and notes 1%
Noncorporate business assets 3%
Other (7) 9%

(1) Gross estate is shown at the value used to determine estate tax
liability. The value can be calculated at the date of death or within
6 months thereafter (i.e, alternate valuation method).

(2) Real estate category includes the value of all real estate, the
value of personal residences, and the value of real estate
partnerships.

(3) Stock category contains the value of corporate stock and stock in a
closely held corporation. The value of mutual funds that are comprised
mainly of stock is also included.

(4) Bonds category contains the value of Federal, State, and local
government bonds, as well as foreign and corporate bonds. The value of
mutual funds that are comprised of Federal, State, local, foreign and
corporate bonds are also included.

(5) Mixed mutual funds category contains the value of funds that
contain assets that are not identified. Therefore, this category may
contain the value of stock, bonds, and other assets in mutual funds.

(6) Money market accounts category contains cash management accounts,
ready asset accounts, and other banking or checking type accounts held
as mutual funds.

(7) Other category contains net value of insurance, depletables and
intangibles, art, and assets not classified elsewere.

NOTE: Detail may not add to toals due to rounding.

Note: Table made from pie chart.

Figure G
Form 706NA Treaty Status Returns, Filing Years
1999 and 2000, by Domicile at Death

 Number of
 returns

 Domicile
 at death 1999 2000

 All countries 350 290
Australia 5 --
Austria 6 4
Canada 127 124
Denmark ** **
Finland 3 **
France 8 8
Germany 70 61
Greece ** **
Ireland -- 3
Italy 13 3
Japan 35 31
Netherlands ** 6
Norway -- **
Scotland -- **
South Africa ** --
Sweden 3 **
Switzerland 14 9
United Kingdom 59 34

** Data deleted to prevent disclosure of individual taxpayer data.
However, the data are included in the appropriate totals.

Figure H
Average Size of U.S. Total Gross Estate and Net
Estate Tax for Form 706NA Treaty Status Returns
Filed in 1999 and 2000, by Domicile at Death

 1999 2000

 U.S. total
 Domicile gross Net U.S. total Net
 at death estate, estate gross estate, estate
 average (1) tax average (1) tax

 (1) (2) (3) (4)

 All countries 962,835 22,916,723 214,366 7,464,058
Australia 438,417 261,328 -- --
Austria 101,615 15,671 526,944 11,163
Canada 220,721 5,060,150 38,414 1,658,773
Finland 176,603 9,012 ** **
France 215,143 151,422 361,220 320,147
Germany 356,897 3,417,584 176,481 635,069
Greece ** ** ** **
Ireland ** ** 168,922 91,500
Italy 554,849 1,062,960 201,898 54,125
Japan 856,395 10,351,462 389,488 1,860,580
Netherlands ** ** 469,858 494,772
Scotland -- -- ** **
South Africa ** ** -- --
Sweden 50,262 12,992 ** **
Switzerland 960,882 2,026,509 767,825 2,044,620
United Kingdom 4,560,245 547,633 695,760 293,309

** Data deleted to prevent individual taxpayer data. However, the data
are included in the appropriate tables.

(1) Gross estate is shown at the value used to determine estate tax
liability. The value could be determined as of date of death or within
6 months thereafter (i.e., alternate valuation method).

Figure I
Average Unified Credit for Form 706NA Treaty
Status Returns Filed in 1999 and 2000, by
Domicile at Death

 Average U.S.
 unified credit
 (1)

Domicile at death 1999 2000

Australia 82,099 --
Austria 13,000 13,000
Canada 38,844 27,658
Finland 38,339 --
France 11,336 13,000
Germany 15,084 11,779
Greece 13,000 --
Ireland -- 13,000
Italy 42,079 24,250
Japan 32,536 34,699
Netherlands 13,000 13,000
Scotland -- 13,000
South Africa 8,113 --
Sweden 13,000 --
Switzerland 50,872 26,492
United Kingdom 21,994 14,929

(1) Unified credit is not present on all treaty returns.

Figure J
Form 706NA Returns with Treaty Status: Composition of U.S. Total
Gross Estate, Filing Years 1999 and 2000 (1)

1999

Real estate (2) 49%
Stock (3) 30%
Bonds (4) 3%
Mixed mutual funds (5) 1%
Money market accounts (6) 1%
Mortgages and notes 2%
Noncorporate business assets 8%
Other (7) 6%

2000

Real estate (2) 55%
Stock (3) 24%
Bonds (4) 1%
Mixed mutual funds (5) 1%
Money market accounts 1%
Cash 4%
Noncorporate business assets 7%
Other (7) 7%

(1) Gross estate is shown at the value used to determine estate tax
liability. The value can be calculated at the date of death or within
6 months thereafter (i.e, alternate valuation method).

(2) Real estate category includes the value of all real estate, the
value of personal residences, and the value of real estate
partnerships.

(3) Stock category contains the value of corporate stock and stock in a
closely held corporation. The value of mutual funds that are comprised
mainly of stock is also included.

(4) Bonds category contains the value of Federal, State, and local
government bonds, as well as foreign and corporate bonds. The value of
mutual funds that are comprised of Federal, State, local, foreign and
corporate bonds are also included.

(5) Mixed mutual funds category contains the value of funds that
contain assets that are not identified. Therefore, this category may
contain the value of stock, bonds, and other assets in mutual funds.

(6) Money market accounts category contains cash management accounts,
ready asset accounts, and other banking or checking type accounts held
as mutual funds.

(7) Other category contains net value of insurance, depletables and
intangibles, art, and assets not classified elsewere.

NOTE: Detail may not add to toals due to rounding.

Note: Table made from pie chart.


Notes and References

[1] World Health Report 1998: Global Health Situations and Trends 1955-2065, 1998. This information is available from the World Wide Web, at http://www.who.int/whr/2001/archives/ 1998/factse.htm

[2] National Center for Health Statistics. This information is available from the World Wide Web, at http://www.cdc.gov/nchs/datawh/ statab/pubd.htm

[3] See Internal Revenue Code section 2032 for a full explanation of alternate value.

Darien Berkowitz Jacobson is an economist with the Special Studies Special Projects Section., This article was prepared under the direction of Michael Alexander, Chief.
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Author:Jacobson, Darien Berkowitz
Publication:Statistics of Income. SOI Bulletin
Geographic Code:1USA
Date:Jun 22, 2002
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