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Federal estate tax returns filed for nonresident aliens, 2001 and 2002.

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 inheritance or on property; instead, it is a tax on the right to transfer property at death.

For Filing Year 2001, the estate tax for U.S. citizens and resident aliens was incurred by estates in which decedents owned $675,000 or more in gross assets. However, the filing threshold of $675,000 increased to $1,000,000 in 2002 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 progressive tax rate structure is applied. In Filing Year 2001, 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. However, in 2002, the highest rate decreases to 50 percent for adjusted taxable estates of more than $2,500,000. 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 2001 and 2002, there were 1,161 Federal estate tax Forms 706NA filed for nonresident alien decedents. The returns received in 2001 and 2002 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 returns that were 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 with less information than regular returns, in part, due to varying reporting practices among countries. The incomplete returns are returns that 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 2001, SOI received 139 regular returns, 371 treaty status returns, and 36 out-of-scope or incomplete returns. SOI saw 137 regular returns, 428 treaty status returns, and 50 out-of-scope or incomplete returns for Filing Year 2002 (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 139 in 2001 and 137 in 2002 (see Figure B). In addition, the total gross estate in the United States of those who filed increased from approximately $50.8 million in 2001 to almost $53.3 million in 2002.

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 2001, about 41.0 percent of estates were in this range, while, in 2002, this percentage increased to 46.0 percent. However, that is where the similarities end because the next two highest groupings were different for 2001 and 2002.

In 2001, the second highest percentage of nonresident alien estates was in the gross estate category of $60,000 under $100,000, with 24.4 percent of the filers in this range. The third highest percentage of nonresident alien estates was in the $250,000 under $500,000 category for 2001 ; this category held 17.3 percent of the total.

In 2002, there were 19.5 percent of the nonresident alien estates in the $250,000 under $500,000 range, making this the second U.S. gross estate category. The third highest category for nonresident alien estates was in the $60,000 under $100,000 range, which was the second highest category for 2001, with approximately 17.5 percent.

For 2001, there were 115 nonresident alien estates that incurred an estate tax liability, and 124 estates that incurred tax liabilities for 2002. The estate tax for 2001 was nearly $9.5 million, while it increased in 2002 to almost $11.5 million.

Citizenship Data

In Filing Year 2001, the average size of U.S. total gross estate was $365,563, 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). Residents of India had the highest average size of U.S. total gross estate, almost $1.8 million, and a net estate tax of $2,474. Estates located in Israel had the second highest average gross estate, $1.7 million, and a higher net estate tax burden than India, almost $2.9 million. The country with the third largest average U.S. gross estate was the Virgin Islands, which reported $889,542 in average gross estate and zero in net estate tax liability.

For Filing Year 2002, the average size of U.S. total gross estate increased slightly to $388,987, and the net estate tax liability increased to about $11.5 million from almost $9.5 million in 2001. In Filing Year 2002, there were no estates that filed a Form 706NA from India or the Virgin Islands, the leader and third largest average U.S. gross estate from 2001. Thailand had the largest average U.S. gross estate for 2002 for estates that filed a Form 706NA, almost $2.5 million, representing a large increase from the previous year since there was no Form 706NA filed in 2001. Thailand had a net estate tax liability of $853,254 million. In 2002, Yugoslavia had the second largest average U.S. gross estate, $1.2 million, and its net estate tax of $51,307. Belgium had the third largest average U.S. gross estate with about $1.0 million, and a net estate tax liability of almost $74,088.

Demographic Data

For 2001 and 2002, the IRS received 139 and 137 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 2001, the number of male decedents totaled 101 (72.7 percent of the total population of regular returns), while female decedents totaled only 38 (27.3 percent). Male decedents for Filing Year 2002 totaled 102 (74.5 percent of the total population of regular returns), and female decedents totaled only 35 (25.5 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 2001 and 2002. The estates of male decedents had 71.8 percent of the estate tax liability for Filing Year 2001, while the estates of female decedents held only 28.1 percent of the estate tax liability for 2001. The estates of male decedents reported almost $6.8 million in estate tax liability for 2001, and the estates of female decedents reported almost $2.7 million. This trend continued for Filing Year 2002. The estates of male decedents were responsible for 53.9 percent of the combined estate tax liability compared to the estates of female decedents, which were responsible for 46.1 percent. This represents approximately $6.2 million in reported estate tax liability for male decedents and $5.3 million in reported liability for female decedents.

For Filing Year 2001, the average age at death for this nonresident alien estate tax population was 71 years (see Figure E). Average age at death decreased by 1 year, to 70, for Filing Year 2002. The average life expectancy for the world in 2002 was 65.2 years, according to the World Heath Report from 2003 [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 2001 was 77.2, 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 decedent's date of death [3].

For Filing Year 2001, the estates of nonresident alien decedents held $26.9 million in real estate, which represented 65.8 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 almost $8.1 million of the combined U.S. gross assets, 19.8 percent of total assets for Filing Year 2001. The cash category was the third largest of all the asset categories. This category accounted for 4.9 percent for U.S. assets held by the estates of nonresident alien decedents in Filing Year 2001. Assets held in the form of cash totaled $2.0 million.

For Filing Year 2002, real estate was again the largest category of assets held in the United States by the estates of nonresident alien decedents. Real estate accounted for $32.3 million or 59.4 percent of the total U.S. assets held by the estates of nonresident alien decedents. Assets in the form of stock were the second largest category of assets for Filing Year 2002. Assets in this form totaled almost $15.1 million or 27.6 percent of the total U.S. assets held by the estates of nonresident aliens. For Filing Year 2002, the bonds category had the third largest holdings. This category included the value of Federal bonds, State and local bonds, corporate bonds, and bond funds. The bonds category totaled $1.9 million, which equaled 3.5 percent of total assets for the estates of nonresident aliens.

Treaty Status Returns

The United States has estate tax treaties with 18 countries: Australia, Austria, Canada, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Japan, the 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 from returns filed by estates from other nontreaty 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 2002 had 57 more treaty status returns than in the Filing Year 2001. This increase of returns filed was consistent across countries. Canada had the most decedents who owned assets in the United States at the date of death, 169 for 2001 and 198 for 2002 (see Figure G). The second highest number of estate filers came from Germany, with 80 returns for 2001 and 84 returns for 2002. The country with the third highest number of returns was the United Kingdom, with 46 returns for 2001 and 54 returns for 2002.

Canada, Germany, and the United Kingdom had the most filers for Filing Years 2001 and 2002. 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 $299,585 for 2001 and $297,976 for 2002 (see Figure H). The United Kingdom ranked third in the number of returns filed for both 2001 and 2002 but had the second largest average size of U.S. gross estate, $320,059 for 2001 and $439,153 for 2002.

The estates of United Kingdom decedents had the second largest average size of U.S. gross estate, but the smallest net estate tax liability for both 2001 and 2002. The net estate tax payable by United Kingdom estates for 2001 was $1.4 million compared to the net estate tax payable for Germany, $7.4 million, and Canada, $4.6 million. For Filing Year 2002, the United Kingdom had a net estate tax liability of almost $2.7 million, while Germany and Canada had net estate tax liabilities of almost $7.6 million and $5.2 million, 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 a credit 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 has an estate tax treaty with the United States. The tax code allows for these estates to use a unified credit equal to the amount that is equivalent to the same ratio of the 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 Canada at the date of death had the highest average unified credit for Filing Year 2001, about $26,116 (see Figure I). Returns filed with estates domiciled in Greece had the second highest average unified credit, $24,867 for Filing Year 2001. The third highest average unified credit was from estates domiciled in Japan, with $23,769.

For Filing Year 2002, the top three countries with the highest average unified credit were different from those for the previous year. The estates from Greece had the highest average unified credit, with $177,775, and the second highest average unified credit of $43,134 was from estates domiciled in Australia. Canada, which had the third highest average unified credit in 2002, about $31,062, dropped from having the highest average unified credit in 2001.

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 $98.5 million in U.S. assets at the date of death, or within 6 months thereafter, for Filing Year 2001. Out of the total assets from treaty status returns, almost $49.2 million, or 49.9 percent, were in the form of real estate (see Figure J). This is the same percentage as returns filed by 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 $32.8 million, or 33.2 percent of the total. However, the similarities between regular return filers and treaty status filers ends with the third largest category of assets, which was the mortgages and notes category. For Filing Year 2001, mortgages and notes totaled just under $5.7 million, which was 5.7 percent of the total assets held in United States treaty status estates.

For Filing Year 2002, 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 was higher than the previous year, up to $117.2 million from $98.5 million. There were some similarities between nonresident alien estates filing in 2001 and 2002; however, the top three categories with the largest amount of assets were the same for treaty status returns and regular returns for Filing Year 2002 with only one exception. The largest type of asset reported on treaty status returns in Filing Year 2002 was real estate, which amounted to $82.5 million and comprised 70.4 percent of total assets. The second largest type of asset held in 2002 for treaty status returns was almost a tie between stocks and the "other" category. The other category included the net value of insurance, depletables and intangibles, annuities, art, and assets that do not tit into any of the categories. Stocks and the other category accounted for 9.5 percent and 9.2 percent of total assets, respectively. Stock totaled $11.1 million, whereas, "other" assets totaled almost $10.8 million. Bonds comprised the third highest category of assets held by nonresident alien estates domiciled in treaty countries. Bonds totaled just under $5.8 million or 4.9 percent of the total.

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 Filing Years 2001 and 2002 was extracted from Forms 706NA 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 countries. Therefore, the information extracted from these Forms 706NA explicitly identified as treaty returns in Filing Years 2001 and 2002 are separated from 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 gifts.

Adjusted taxable gifts.--Certain gifts 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 gift 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, is 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 that 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 2001:
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 purposes Total gross estate,
 (1) outside the U.S.

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

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

 All returns, total 139 50,813,220 139 47,540,957
Less than $100,000 34 2,561,874 34 5,364,159
$100,000 under $500,000 81 17,003,303 81 28,471,761
$500,000 or more 24 31,248,043 24 13,705,037

 Nontaxable returns, total 24 7,810,362 24 4,108,866
Less than $100,000 10 666,655 10 266,485
$100,000 under $500,000 11 2,210,465 11 1,269,576
$500,000 or more 3 4,933,242 3 2,572,805

 Taxable returns, total 115 43,002,858 115 43,432,091
Less than $100,000 24 1,895,219 24 5,097,674
$100,000 under $500,000 70 14,792,838 70 27,202,185
$500,000 or more 21 26,314,801 21 11,132,232

 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 139 98,354,180 96 26,901,955
Less than $100,000 34 7,926,033 23 1,776,703
$100,000 under $500,000 81 45,475,067 50 9,127,142
$500,000 or more 24 44,953,080 23 15,998,110

 Nontaxable returns, total 24 11,919,228 15 5,298,029
Less than $100,000 10 933,140 7 486,900
$100,000 under $500,000 11 3,480,041 5 1,101,900
$500,000 or more 3 7,506,047 3 3,709,229

 Taxable returns, total 115 86,434,952 81 21,603,926
Less than $100,000 24 6,992,893 16 1,289,803
$100,000 under $500,000 70 41,995,026 45 8,025,242
$500,000 or more 21 37,447,033 20 12,288,881

 Bonds
 Stocks (3) (4)

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

 (9) (10) (11)

 All returns, total 47 8,098,049 16
Less than $100,000 7 419,329 5
$100,000 under $500,000 36 5,261,348 11
$500,000 or more 4 2,417,372 --

 Nontaxable returns, total 8 1,763,978 3
Less than $100,000 ** ** --
$100,000 under $500,000 ** 8 ** 1,763,978 3
$500,000 or more ** ** --

 Taxable returns, total 39 6,334,071 13
Less than $100,000 ** ** 5
$100,000 under $500,000 ** 39 ** 6,334,071 8
$500,000 or more ** ** --

 Mixed mutual
 Bond (4) funds (5) Cash

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

 (12) (13) (14) (15)

 All returns, total 1,149,361 8 526,018 17
Less than $100,000 166,834 ** ** **
$100,000 under $500,000 982,527 ** 8 ** 526,018 ** 11
$500,000 or more -- -- -- 6

 Nontaxable returns, total 374,424 3 ** 276,505 3
Less than $100,000 -- ** ** **
$100,000 under $500,000 374,424 -- ** 276,505 ** 3
$500,000 or more -- -- -- **

 Taxable returns, total 774,937 5 249,513 14
Less than $100,000 166,834 ** ** **
$100,000 under $500,000 608,103 ** 5 ** 249,513 ** 14
$500,000 or more -- -- -- **

 Money market
 Cash accounts (6)

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

 (16) (17) (18)

 All returns, total 2,023,350 10 443,842
Less than $100,000 ** 3 20,036
$100,000 under $500,000 ** 104,216 ** 7 ** 423,806
$500,000 or more 1,919,134 ** **

 Nontaxable returns, total 46,034 3 141,351
Less than $100,000 ** ** 3 ** 141,351
$100,000 under $500,000 ** 46,034 ** **
$500,000 or more ** -- --

 Taxable returns, total 1,977,316 7 302,491
Less than $100,000 ** ** **
$100,000 under $500,000 ** 1,977,316 ** 7 ** 302,491
$500,000 or more ** ** **

 Insurance,
 net value Limited partnerships

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

 (19) (20) (21) (22)

 All returns, total ** ** 6 8,576,409
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** ** ** 6 ** 8,576,409
$500,000 or more ** ** ** **

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

 Taxable returns, total ** ** 6 8,576,409
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** ** ** 6 ** 8,576,409
$500,000 or more ** ** ** **

 Noncorporate
 business assets Mortgages and notes
 (7)

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

 (23) (24) (25) (26)

 All returns, total -- -- 4 1,240,933
Less than $100,000 -- -- ** **
$100,000 under $500,000 -- -- ** 4 ** 1,240,933
$500,000 or more -- -- ** **

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

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

 Funeral
 Other assets (8) expenses

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

 (27) (28) (29)

 All returns, total 26 1,852,127 41
Less than $100,000 3 16,600 9
$100,000 under $500,000 16 332,499 25
$500,000 or more 7 1,503,028 7

 Nontaxable returns, total 3 115,600 6
Less than $100,000 ** ** ** 6
$100,000 under $500,000 ** 3 ** 115,600 **
$500,000 or more ** ** **

 Taxable returns, total 23 1,736,527 35
Less than $100,000 ** ** 5
$100,000 under $500,000 ** 23 ** 1,736,527 ** 30
$500,000 or more ** ** **

 Attor-
 Funeral Executors' neys'
 expenses commissions fees

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

 (30) (31) (32) (33)

 All returns, total 400,412 8 659,842 29
Less than $100,000 31,493 -- -- 3
$100,000 under $500,000 277,428 5 368,659 17
$500,000 or more 91,491 3 291,183 9

 Nontaxable returns, total 14,925 -- -- **
Less than $100,000 ** 14,925 -- -- **
$100,000 under $500,000 ** -- -- **
$500,000 or more ** -- -- **

 Taxable returns, total 385,487 8 659,842 ** 29
Less than $100,000 24,438 -- -- **
$100,000 under $500,000 ** 361,049 5 368,659 **
$500,000 or more ** 3 291,183 **

 Attorneys'
 fees Other expenses/losses

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

 (34) (35) (36)

 All returns, total 1,458,933 49 2,016,230
Less than $100,000 13,224 12 289,698
$100,000 under $500,000 520,438 34 1,483,172
$500,000 or more 925,271 11 450,774

 Nontaxable returns, total ** 8 207,414
Less than $100,000 ** 5 20,468
$100,000 under $500,000 ** ** 3 ** 186,946
$500,000 or more ** ** **

 Taxable returns, total ** 1,458,933 49 2,016,230
Less than $100,000 ** 7 269,230
$100,000 under $500,000 ** ** 42 ** 1,747,000
$500,000 or more ** ** **

 Marital and
 Debts and mortgages charitable
 deductions

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

 (37) (38) (39)

 All returns, total 41 23,213,486 17
Less than $100,000 7 311,322 --
$100,000 under $500,000 23 2,422,985 ** 11
$500,000 or more 11 20,479,179 **

 Nontaxable returns, total 8 14,253,187 7
Less than $100,000 ** 8 ** 14,253,187 --
$100,000 under $500,000 ** ** 7
$500,000 or more ** ** --

 Taxable returns, total 33 8,960,299 4
Less than $100,000 ** ** --
$100,000 under $500,000 ** 33 ** 8,960,299 ** 4
$500,000 or more ** ** **

 Marital and
 charitable Total allowable
 deductions deductions

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

 (40) (41) (42)

 All returns, total 2,516,210 72 18,170,449
Less than $100,000 -- 14 311,927
$100,000 under $500,000 ** 2,516,210 44 3,068,277
$500,000 or more ** 14 14,790,245

 Nontaxable returns, total 1,634,882 16 13,347,597
Less than $100,000 -- 6 235,084
$100,000 under $500,000 1,634,882 ** 10 ** 13,112,573
$500,000 or more -- ** **

 Taxable returns, total 881,328 56 4,822,852
Less than $100,000 -- 8 76,843
$100,000 under $500,000 ** 881,328 ** 48 ** 4,746,009
$500,000 or more ** ** **

 Adjusted
 Taxable estate taxable
 estate

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

 (43) (44) (45)

 All returns, total 126 37,722,717 126
Less than $100,000 33 2,273,385 33
$100,000 under $500,000 72 13,523,519 72
$500,000 or more 21 21,925,813 21

 Nontaxable returns, total 11 634,274 11
Less than $100,000 ** 11 ** 634,274 ** 11
$100,000 under $500,000 ** ** **
$500,000 or more -- -- --

 Taxable returns, total 115 37,088,443 115
Less than $100,000 24 1,818,374 24
$100,000 under $500,000 ** 91 ** 35,270,069 ** 91
$500,000 or more ** ** **

 Adjusted
 taxable Estate tax before
 estate credits

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

 (46) (47) (48)

 All returns, total 37,722,717 125 12,544,763
Less than $100,000 2,273,385 33 509,030
$100,000 under $500,000 13,523,519 71 3,672,309
$500,000 or more 21,925,813 21 8,363,424

 Nontaxable returns, total 634,274 10 108,275
Less than $100,000 ** 634,274 ** 10 ** 108,275
$100,000 under $500,000 ** ** **
$500,000 or more -- -- --

 Taxable returns, total 37,088,443 115 12,436,488
Less than $100,000 1,818,374 24 411,693
$100,000 under $500,000 ** 35,270,069 ** 91 ** 12,024,796
$500,000 or more ** ** **

 Allowable unified State death
 credit tax credit

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

 (49) (50) (51)

 All returns, total 121 1,570,534 50
Less than $100,000 30 370,337 **
$100,000 under $500,000 71 940,197 ** 35
$500,000 or more 20 260,000 15

 Nontaxable returns, total 11 121,275 --
Less than $100,000 ** 11 ** 121,275 --
$100,000 under $500,000 ** ** --
$500,000 or more -- -- --

 Taxable returns, total 110 1,449,259 50
Less than $100,000 21 273,000 **
$100,000 under $500,000 ** 89 ** 1,176,259 ** 35
$500,000 or more ** ** 15

 State
 death tax Other credits
 credit

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

 (52) (53) (54)

 All returns, total 366,676 6 1,155,395
Less than $100,000 ** -- --
$100,000 under $500,000 ** 59,035 3 113,022
$500,000 or more 307,641 3 1,042,373

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

 Taxable returns, total 366,676 6 1,155,395
Less than $100,000 ** -- --
$100,000 under $500,000 ** 59,035 3 113,022
$500,000 or more 307,641 3 1,042,373

 Net estate tax

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

 (55) (56)

 All returns, total 115 9,465,159
Less than $100,000 24 138,475
$100,000 under $500,000 70 2,573,273
$500,000 or more 21 6,753,411

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

 Taxable returns, total 115 9,465,159
Less than $100,000 24 138,475
$100,000 under $500,000 70 2,573,273
$500,000 or more 21 6,753,411

** 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 (i.e., alternate valuation method).

(2) Real estate category includes the value of all real estate,
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 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.

(8) Other category contains depletables and intangibles, art, and
assets not classified elsewhere.

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

Table 2.--Nonresident Alien Estate Tax Returns Filed in 2002: 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 Total gross
 estate, U.S., estate, outside
 tax purposes (1) the U.S.

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 137 53,291,181 137 130,408,095
Less than $100,000 24 1,736,660 24 16,497,326
$100,000 under $500,000 89 20,024,753 89 78,551,062
$500,000 or more 24 31,529,768 24 35,359,707

 Nontaxable returns,
 total 13 6,159,122 13 3,930,990
Less than $100,000 5 299,301 5 3,463,498
$100,000 under $500,000 5 665,929 5 406,992
$500,000 or more 3 5,193,892 3 60,500

 Taxable returns, total 124 47,132,059 124 126,477,105
Less than $100,000 19 1,437,359 19 13,033,828
$100,000 under $500,000 84 19,358,824 84 78,144,070
$500,000 or more 21 26,335,876 21 35,299,207

 Total gross Real estate (2)
 estate,
 worldwide

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 137 183,699,274 82 32,355,927
Less than $100,000 24 18,233,986 11 858,684
$100,000 under $500,000 89 98,575,813 53 11,819,389
$500,000 or more 24 66,889,475 18 19,677,854

 Nontaxable returns,
 total 13 10,090,112 7 4,444,696
Less than $100,000 5 3,762,799 ** **
$100,000 under $500,000 5 1,072,921 **4 ** 369,446
$500,000 or more 3 5,254,392 3 4,075,250

 Taxable returns, total 124 173,609,162 75 27,911,231
Less than $100,000 19 14,471,187 ** **
$100,000 under $500,000 84 97,502,892 **60 ** 12,308,627
$500,000 or more 21 61,635,083 15 15,602,604

 Stocks (3) Bonds (4)

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 52 15,058,621 10 1,917,836
Less than $100,000 8 553,405 -- --
$100,000 under $500,000 30 7,972,810 5
$500,000 or more 14 6,532,406 5 1,002,902
 914,934
 Nontaxable returns,
 total 6 526,186 ** **
Less than $100,000 ** 6 ** 526,186 -- --
$100,000 under $500,000 ** ** -- --
$500,000 or more ** ** ** **

 Taxable returns, total 46 14,532,435 ** **
Less than $100,000 4 261,647 -- --
$100,000 under $500,000 ** 42 ** 142,707,88 ** **
$500,000 or more ** ** ** **

 Mixed mutual
 funds (5) Cash

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 10 1,008,233 19 496,685
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** 7 ** 883,668 ** 16 ** 489,532
$500,000 or more 3 491,638 3 7,153

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

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

 Money market Insurance,
 accounts (6) net value

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 16 1,021,734 ** **
Less than $100,000 -- -- -- --
$100,000 under $500,000 11 748,523 -- --
$500,000 or more 5 273,211 ** **

 Nontaxable returns,
 total 3 118,713 -- --
Less than $100,000 -- -- -- --
$100,000 under $500,000 ** ** -- --
$500,000 or more ** ** -- --

 Taxable returns, total 13 903,021 ** **
Less than $100,000 -- -- -- --
$100,000 under $500,000 10 747,797 -- --
$500,000 or more 3 155,224 ** **

 Noncorporate
 Limited business
 partnerships assets (7)

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total -- -- 3 1,462,147
Less than $100,000 -- -- -- --
$100,000 under $500,000 -- -- ** **
$500,000 or more -- -- ** **

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

 Taxable returns, total -- -- 3 1,462,147
Less than $100,000 -- -- -- --
$100,000 under $500,000 -- -- ** **
$500,000 or more -- -- ** **

 Mortgages and
 notes Other assets (8)

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total ** ** 33 1,087,499
Less than $100,000 -- -- 3 151,289
$100,000 under $500,000 ** ** 20 551,431
$500,000 or more -- -- 10 384,779

 Nontaxable returns,
 total ** ** ** 5 ** 149,054
Less than $100,000 -- -- ** **
$100,000 under $500,000 ** ** ** 5 ** 149,054
$500,000 or more -- -- ** **

 Taxable returns, total -- -- 28 938,445
Less than $100,000 -- -- ** **
$100,000 under $500,000 -- -- ** 28 ** 938,445
$500,000 or more -- -- ** **

 Executors'
 Funeral expenses commissions

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 26 1,182,611 3 39,441
Less than $100,000 3 918,014 -- --
$100,000 under $500,000 14 162,643 ** 3 39,441
$500,000 or more 9 101,954 ** **

 Nontaxable returns,
 total 3 918,714 -- --
Less than $100,000 ** 3 ** 918,714 -- --
$100,000 under $500,000 -- -- -- --
$500,000 or more -- -- -- --

 Taxable returns, total 23 263,897 3 39,441
Less than $100,000 ** ** -- --
$100,000 under $500,000 ** 23 ** 263,897 ** 3 ** 39,441
$500,000 or more ** ** ** **

 Attorneys' fees Other expenses/losses

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 24 649,974 40 1,489,953
Less than $100,000 3 16,750 4 376,443
$100,000under $500,000 13 199,130 25 460,524
$500,000 or more 8 434,094 11 652,986

 Nontaxable returns,
 total 3 30,724 3 454,854
Less than $100,000 ** 3 ** 30,724 ** 3 * 454,854
$100,000 under $500,000 -- -- -- --
$500,000 or more ** ** ** **

 Taxable returns, total 21 619,250 37 1,035,099
Less than $100,000 ** ** ** **
$100,000 under $500,000 ** 21 ** 619,250 ** 37 ** 1,035,099
$500,000 or more ** ** ** **

 Marital and
 charitable
 Debts and mortgages deductions

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 18 3,670,298 12 6,820,069
Less than $100,000 -- -- -- --
$100,000under $500,000 10 871,246 4 311,583
$500,000 or more 8 2,799,052 8 6,508,486

 Nontaxable returns,
 total ** ** 5 4,306,709
Less than $100,000 -- -- -- --
$100,000 under $500,000 -- -- ** **
$500,000 or more ** ** ** 5 ** 4,306,709

 Taxable returns, total ** 18 ** 3,670,298 7 2,513,360
Less than $100,000 -- -- -- --
$100,000 under $500,000 10 871,246 ** **
$500,000 or more ** 8 ** 2,799,052 ** 7 ** 2,513,360

 Total allowable
 deductions Taxable estate

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 76 11,397,808 137 41,888,358
Less than $100,000 8 38,388 24 1,698,270
$100,000 under $500,000 48 1,987,797 89 18,031,944
$500,000 or more 20 9,371,623 24 22,158,144

 Nontaxable returns,
 total 11 5,405,987 13 753,133
Less than $100,000 3 15,272 5 284,027
$100,000 under $500,000 5 376,821 5 289,108
$500,000 or more 3 5,013,894 3 179,998

 Taxable returns, total 65 5,991,821 124 41,135,225
Less than $100,000 5 23,116 19 1,414,243
$100,000 under $500,000 43 1,610,976 84 17,742,836
$500,000 or more 17 4,357,729 21 21,978,146

 Adjusted taxable Estate tax before
 estate credits

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 137 41,888,357 137 13,900,303
Less than $100,000 24 1,698,270 24 380,182
$100,000 under $500,000 89 18,031,944 89 5,042,735
$500,000 or more 24 22,158,143 24 8,477,386

 Nontaxable returns,
 total 13 753,133 13 162,781
Less than $100,000 5 284,027 5 61,166
$100,000 under $500,000 5 289,108 5 62,615
$500,000 or more 3 179,998 3 39,000

 Taxable returns, total 124 41,135,224 124 13,737,522
Less than $100,000 19 1,414,243 19 319,016
$100,000 under $500,000 84 17,742,836 84 4,980,120
$500,000 or more 21 21,978,145 21 8,438,386

 Allowable unified State death tax
 credit credit

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

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

 All returns, total 135 1,822,897 54 2,408,728
Less than $100,000 23 295,294 -- --
$100,000 under $500,000 88 1,215,603 41 120,673
$500,000 or more 24 312,000 13 2,288,055

 Nontaxable returns,
 total 13 160,006 -- --
Less than $100,000 5 61,294 -- --
$100,000 under $500,000 5 59,712 -- --
$500,000 or more 3 39,000 -- --

 Taxable returns, total 122 1,662,891 54 2,408,728
Less than $100,000 18 234,000 -- --
$100,000 under $500,000 83 1,155,891 41 120,673
$500,000 or more 21 273,000 13 2,288,055

 Other credits Net estate tax

 Tax status, size of Num- Num-
 U.S. gross estate ber Amount ber Amount

 (53) (54) (55) (56)

 All returns, total 4 76,048 124 11,466,367
Less than $100,000 -- -- 19 85,016
$100,000 under $500,000 ** 4 ** 76,048 84 3,718,017
$500,000 or more ** ** 21 7,663,334

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

 Taxable returns, total ** ** 124 11,466,367
Less than $100,000 -- -- 19 85,016
$100,000 under $500,000 ** ** 84 3,718,017
$500,000 or more ** ** 21 7,663,334

** 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 (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
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.

(8) Other category contains depletables and intangibles, art,
and assets not classified elsewhere.

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

Figure A
Form 706NA Returns Filed in 2001 and 2002, by
Tyne of Return
 2001 2002

Item Percentage Percentage
 Number oftotal Number of total

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

Total 546 100.0 615 100.0
Regular returns 139 25.5 137 20.3
Treaty status returns 371 67.9 428 71.5
Incomplete/out-of-scope 36 6.6 50 8.1

NOTE: Detail may not add to 100 percent due to rounding.

Figure B
Form 706NA Returns Filed in 2001 and 2002: Number of Returns and
U.S. Total Gross Estate, by Size of U.S. Total Gross Estate

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

 2001

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

 (1) (2) (3)

 Total 139 100.0 50,813,220
Less than $60,000 (2) ** ** **
$60,000 under $100,000 ** 34 24.4 ** 2,561,874
$100,000 under $250,000 57 41.0 8,932,199
$250,000 under $500,000 24 17.3 8,071,104
$500,000 under $1 million 15 10.8 10,804,571
$1 million or more 9 6.5 20,443,472

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

 2002

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

 (4) (5) (6)

 Total 137 100.0 53,291,181
Less than $60,000 (2) -- -- --
$60,000 under $100,000 24 17.5 1,736,660
$100,000 under $250,000 63 46.0 10,130,187
$250,000 under $500,000 26 19.5 9,894,566
$500,000 under $1 million 13 9.5 8,527,951
$1 million or more 11 8.0 23,001,817

** 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 could be determined as of date of death or 6
months thereafter (i.e., alternate valuation).

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

NOTE: Detail may not add to 100 percent due to rounding.

Figure C
Form 706NA Returns: Average Size of U.S. Total Gross Estate and Net
Estate Tax, by Domicile at Death, Filing Years 2001-2002

 2001 2002

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

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

All countries 365,563 9,465,159 388,987 11,466,367
 Africa 198,142 34,433 81,609 5,651
 Antilles 139,731 22,401 -- --
 Argentina 154,786 117,073 248,183 143,102
 Aruba -- -- 53,573 --
 Bahamas -- -- 140,192 14,540
 Barbados 781,988 234,692 -- --
 Belgium 578,496 555,918 1,049,687 74,088
 Bermuda 112,000 5,805 -- --
 Bolivia 115,000 15,180 -- --
 Brazil 522,383 815,547 478,720 939,383
 Caicos Islands 151,425 23,456 -- --
 Chile -- -- 260,896 52,705
 China 397,506 656,170 620,165 2,557,325
 Colombia 119,619 117,938 143,650 141,412
 Costa Rica 71,242 2,600 -- --
 Croatia 148,730 25,419 -- --
 Djibouti 316,000 60,757 -- --
 Dominican Republic 121,000 16,932 -- --
 Ecuador 151,996 258,671 164,536 85,040
 Egypt 771,966 243,516 440,707 247,954
 Gabon -- -- 532,073 142,860
 Ghana -- -- 153,222 26,183
 Guam 204,102 7,429 380,890 61,740
 Guatemala 317,500 71,200 100,000 10,800
 Haiti 80,000 -- -- --
 Honduras -- -- 530,000 142,700
 Hungary 84,000 5,598 -- --
 India 1,756,609 2,474 -- --
 Israel 1,726,701 2,883,122 258,743 247,357

 2001 2002

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

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

All countries
 Jamaica 80,576 5,361 167,046 --
 Jordan 219,000 -- 117,333 700
 Lebanon 319,423 217,871 -- --
 Luxembourg 137,500 21,430 -- --
 Mexico 407,194 1,805,253 235,617 518,381
 Nepal -- -- 610,958 260
 New Zealand 150,093 24,921 177,904 66,038
 Pakistan 720,205 81,478 502,140 416,049
 Paraguay -- -- 498,720 132,406
 Peru -- -- 106,404 47,624
 Philippines 275,000 59,166 575,613 344,615
 Poland -- -- 207,891 44,325
 Portugal; Azores -- -- -- 171,970
 Puerto Rico 193,886 215,945 384,222 1,137,700
 Russia 251,450 58,293 845,229 --
 Saudi Arabia 90,262 19,460 -- --
 Singapore 119,879 30,872 268,125 118,984
 South America -- -- 411,551 112,727
 South Korea -- -- 100,687 11,006
 Spain 312,222 224,032 442,425 498,541
 Taiwan 701,183 197,811 131,095 67,338
 Thailand -- -- 2,449,400 853,254
 Trinidad and Tobago -- -- 454,369 127,285
 Turkey -- -- 448,112 328,826
 Venezuela 169,464 326,935 447,043 1,513,964
 Vietnam -- -- 82,587 5,924
 Virgin Islands 889,542 -- -- --
 Yugoslavia -- -- 1,216,240 51,307
 Zimbabwe -- -- 76,550 4,303

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

Figure D
Form 706NA Returns Filed in 2001 and 2002, Selected Items by
Sex of Decedent

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

 2001

Sex of Number Percentage
decedent of returns of total Amount

 (1) (2) (3)

Total 139 100.0 50,813,220
Male 101 72.7 37,079,438
Female 38 27.3 13,733,782

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

 2002

Sex of Number Percentage
decedent of returns of total Amount

 (4) (5) (6)

Total 137 100.0 53,291,181
Male 102 74.5 35,334,978
Female 35 25.5 17,956,203

 Net estate tax

 2001 2002

Sex of Percentage Percentage
decedent Amount of total Amount of total

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

Total 9,465,159 100.0 11,466,367 100.0
Male 6,798,533 71.8 6,178,074 53.9
Female 2,666,626 28.1 5,288,293 46.1

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

NOTE: Detail may not add to 100 percent due to rounding.

Figure E
Form 706NA Returns Filed in 2001 and 2002,
by Sex and Average Age of Decedent

 2001 2002

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

All 139 71 137 70
Male 101 71 102 70
Female 38 71 35 73

Figure F
Nonresident Alien Estates: Composition of U.S. Total Gross Estate,
Filing Years 2001 and 2002 (1)

2001

Real estate (2) 65.8%
Stocks (3) 19.8%
Bonds (4) 2.8%
Mixed Mutual funds (5) 1.3%
Cash 4.9%
Money market accounts (6) 1.1%
Mortgages and notes 3.0%
Noncorporate business assets 0.0%
Other (7) 1.2%

Note: Table made from pie chart.

2002

Real estate (2) 59.4%
Stocks (3) 27.6%
Bonds (4) 3.5%
Mixed Mutual funds (5) 1.8%
Cash 0.9%
Money market accounts (6) 1.9%
Mortgages and notes 0.2%
Noncorporate business assets 2.7%
Other (7) 2.0%

Note: Table made from pie chart.

(1) Gross estate is shown at the value used to determine estate tax
liability and excludes the value of limited partnerships. 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 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) Other category contains insurance, depletables, and intangibles,
art, and assets not classified elsewhere.

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

Figure G
Form 706NA Treaty Status Returns, by Domicile
at Death, Filing Years 2001 and 2002

 Number of
 returns
 2001 2002

Domicile at death 2001 2002

All countries 371 428
 Australia 4 10
 Austria -- 3
 Canada 169 198
 Denmark -- --
 Finland -- --
 France 11 12
 Germany 80 84
 Greece 4 **
 Ireland 5 8
 Italy 4 11
 Japan 26 21
 Netherlands 4 5
 Norway -- **
 Scotland 3 --
 South Africa ** **
 Sweden ** 5
 Switzerland 8 12
 United Kingdom 46 54

** 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 2001 and 2002, by Domicile at
Death

 2001 2002

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

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

All countries 962,835 20,589,256 439,565 22,216,274
 Australia 359,265 322,733 380,682 408,653
 Austria -- -- 251,455 148,836
 Canada 299,585 4,632,941 297,976 5,243,804
 Denmark -- -- -- --
 Finland -- -- -- --
 France 1,045,883 2,632,806 2,075,718 360,422
 Germany 384,315 7,417,885 508,160 7,597,138
 Greece 9,253,920 1,011 559,392 --
 Ireland 351,162 278,146 659,762 1,351,369
 Italy 428,823 144,124 380,888 472,080
 Japan 471,603 3,166,049 416,239 1,244,214
 Netherlands 396,495 22,625 783,148 975,240
 Norway -- -- 419,518 220,341
 Scotland 356,079 -- -- --
 South Africa 762,229 288,549 224,414 78,140
 Sweden 182,500 58,295 202,672 128,043
 Switzerland 183,183 213,909 740,184 1,290,075
 United Kingdom 320,059 1,410,183 439,153 2,697,919

(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 2001 and 2002, by
Domicile at Death

 Average U.S.
 unifect
 credit (1)

Domicile at death 2001 2002

All countries 18,601 23,014
Australia 18,940 43,134
Austria -- 12,974
Canada 26,116 31,062
Denmark -- --
Finland -- --
France 8,273 5,417
Germany 11,722 14,288
Greece 24,867 177,775
Ireland 10,400 9,750
Italy 13,000 39,827
Japan 23,769 21,355
Netherlands 6,500 5,200
Norway -- 13,000
Scotland -- --
South Africa 13,000 13,000
Sweden 13,000 10,400
Switzerland 18,644 25,374
United Kingdom 7,909 6,079

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

Figure J
Nonresident Alien Estates: Composition of U.S. Total Gross Estate,
Filing Years 2001 and 2002 (1)

2001

Real estate (2) 49.9%
Stocks (3) 33.2%
Bonds (4) 2.3%
Mixed Mutual funds (5) 1.2%
Cash 2.7%
Money market accounts (6) 0.6%
Mortgages and notes 5.7%
Noncorporate business assets 0.0%
Other (7) 4.2%

Note: Table made from pie chart.

2002

Real estate (2) 70.4%
Stocks (3) 9.5%
Bonds (4) 4.9%
Mixed Mutual funds (5) 1.3%
Cash 2.6%
Money market accounts (6) 0.5%
Mortgages and notes 0.3%
Noncorporate business assets 1.2%
Other (7) 9.2%

Note: Table made from pie chart.

(1) Gross estate is shown at the value used to determine estate tax
liability and excludes the value of limited partnerships. 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 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) Other category contains insurance, depletables, and intangibles,
art, and assets not classified elsewhere.

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


Notes and References

[1] World Health Report 2003. Shaping the Future. This information is available from the World Wide Web at http://www.who.int/whr/ 2003/en/Facts_and_Figures-en.pdf.

[2] National Center for Health Statistics. This information is available from the World Wide Web at http://www.cdc.gov/nchs/products/pubs/ pubd/1ftbls/life/1966.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 Branch Special Projects Section. This article was written under the direction of Barry Johnson, Chief
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Author:Jacobson, Darien Berkowitz
Publication:Statistics of Income. SOI Bulletin
Geographic Code:1USA
Date:Jun 22, 2004
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